905R80100
00471
                    QUALITY ASSURANCE PROGRAM
                  GUIDELINES AND SPECIFICATIONS
                    CRITERIA AND PROCEDURES
                           REGION V

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                           TABLE OF CONTENTS
                                                                   PAGE

1.  Identification of Office of Laboratory Submitting QA Plan	1

2.  Quality Assurance Policy Statement, Region V	3

3.  Objectives and Milestones	5

4.  Quality Assurance Management	7
    4.1    Introduction.	7
    4.2    Quality Assurance Management Plan	8
    4.2.1  Assignment of Responsibilities	9
    4.2.2  Flow of Information	11
    4.2.3  Identification of QA - Related Committees or Meetings	12
    4.2.4  Description of Needs	13

5.  Personnel	14

6.  Facilities, Equipment and Services	17

7.  Review of Program Plans, Project Plans or Study Plans	18

8.  Data C ol 1 ecti on	20
    8.1      Sampling Plan	20
    8.2      Sampling Methodology	21
    8.3      Analytical  Methodology	32
    8.3.1    Maintenance of Up-To-Date File of Measurement Methods...37
    8.3.2    Alternate Test Procedure Program	40
    8.3.2.1  Elements of an Application for a National  Pollutant
               Discharge Elimination System (NPDES) of Section 106
               Alternate Test Procedure	41
    8.3.2.2  Elements of an Application for a Safe Drinking
               Water Act (SDWA) Alternate Test Procedure	48
    8.3.2.3  Processing of Case-By-Case Alternate Test  Procedure
               in Region V	51
    8.3.2.4  Procedures for Equivalent Test Procedure Under the
               Clean Air Act	53
    8.4      Instrument at i on	53
    8.5      Calibration and Standards	54
    8.6      Preventive Maintenance and Inspections	55
    8.7      Qua! i ty C ontrol Procedures	57
    8.7.1    Intra-Laboratory Quality Control Procedures...	57
    8.7.1.2  Intra-Field Quality Control  Procedures	63
    8.7.1.3  Additional  Intra-Laboratory Quality Control
               Procedures for Specific Groups of Parameters	65
    8.7.2    Inter-Laboratory Quality Control Procedures	71

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                      TABLE  OF CONTENTS  (CONTINUED)
                                                                    PAGE          I

     8.7.2.1  Management of  the  Accuracy and Performance
                Audit Programs	72          •
     8.7.2.2  Management of  the  On-Site  System Evaluation  of Total                |
                In-House, Federal,  State and Local  Agency,
                Contractor,  Grantee Monitoring Program	76          _

 9.  Data Processing	78          •
     9.1  Data Handling Transmission and Storage	78
     9.2  Data Validation and Verification	86          •
     9.3  Data Reduction (Including Software QC  Considerations)	92          |

10.  Corrective Actions	93          •
     10.1  QA Management	95          •
     10.2  QC Management	95          ™

11.  Data Quality Assessment	97          •
     11.1  Accuracy Assessment	98          I
     11.2  Precision Assessment	98
     11.3  Completeness Assessment	98          •
     11.4  Represent!'veness  Assessment	98          |
     11.5  Overall Data Quality  Assessment	99

12.  Data Quality Reports (QC and QA)	99          I

13.  Chain of Custody	100

14.  Specific Guidance	106          |
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APPENDIX 1
APPENDIX 2
APPENDIX 3
APPENDIX 4

APPENDIX 5

APPENDIX 6

APPENDIX 7
APPENDIX 8
APPENDIX 9
APPENDIX 10
APPENDIX 11

APPENDIX 12

APPENDIX 13
APPENDIX 14
APPENDIX 15



                APPENDICES

Quality Assurance Office FY 80 Work Plan

Relationship of the Quality Assurance Function to
Other Regional  Program Functions

The Organizational  Structure of Region V

State of Wisconsin Department of Natural Resources,
Bureau of Air Management, Air Monitoring Section,
Quality Assurance Manual - Procurement

Sample Collection Containers, Preservatives and Holding
Times for Sample Collection in the 106, 208,  404(b)(l)
and the Great Lakes National Monitoring Programs

EPA Official Analytical  Methodology - Priority Pollutant
Measurements

EPA Official Analytical  Methodology - Hazardous Waste
Measurements

Sample Collection, Preservation, and Holding  Times  -
Ambient Air Samples

EPA Official Analytical  Methodology - Water Quality
Measurements

EPA Official Analytical  Methodology - Radiation Methods

EPA Official Analytical  Methodology - Ambient Air
Measurements

EPA Official Analytical  Methodology - Source  Air
Measurements

EPA Offical Analytical  Methodology - Public Water
Supply Methods

Sample Collection Containers, Preservatives,  and Holding
Times for Samples Collected in the 1412 Monitoring  Program

Approved Alternative Analytical  Methods -  Nationwide Use.

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APPENDIX 16




APPENDIX 17


APPENDIX 18



APPENDIX 19



GLOSSARY
          APPENDICES (Continued)

Performance Tests for the Evaluation  of Computerized
Gas Chromatography/Mass Spectrometry  Equipment  and
Laboratories

Life Cycle of an On-Site System Evaluation

Elements for a Section 106,  208,  404(b)(l)  and  Great
Lakes Program Monitoring Quality  Assurance  Program

Summary of Guidelines for Station Siting  and Probe
Placement
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1.   IDENTIFICATION OF OFFICE  OR  LABORATORY  SUBMITTING QA PLAN
    Document Title:
    Units Full  Name
      and Address:
    Individual
      Responsible:
    Individual
      Responsible
      for QA:
    Plan Prepared By:
    Submission Date:

    Calendar Year
      Covered:
Quality Assurance Program
Guidelines and Specifications
Criteria and Procedures
Region V
Ref. NO.:
EPA-905/4-80-001
U.S. Environmental Protection Agency
230 South Dearborn Street
Chicago, Illinois 60604

John McGuire
Regional Administrator
Region V
U.S. Environmental Protection Agency
230 South Dearborn Street
Chicago, Illinois 60604
(FTS)353-2000

William H. Sanders III
Director
Surveillance and Analysis Division
U.S. Environmental Protection Agency
Region V
536 South Clark Street
Chicago, Illinois 60605
(FTS)353-3808

James H. Adams, Jr.
Chief
Quality Assurance Office
Surveillance and Analysis Division
U.S. Environmental Protection Agency
Region V
536 South Clark Street
Chicago, Illinois 60605
(FTS)353-9604

January 15, 1980

Interim document will be used pending finalization
of Agency Quality Assurance Plan.
    Summary of environmental  monitoring  or measurement  activities performed
    by Region V:

    Quality assurance activities  have  been planned  for  1980 in Air
    Quality Monitoring,  Air Enforcement,  Dredge  and Fill, Ambient Water
    Quality Monitoring,  Water Quality  Enforcement,  Public Water Supply
    Management and Great Lakes Monitoring.   There are also special
    studies, contracts and  other  activities  that require evaluation
    for quality assurance.

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INTRODUCTION
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Environmental  Protection Agency (EPA)  Policy,  enunciated  in  memoranda        •
of May 30 and June 14, 1979,  requires  participation  in  a  centrally-managed   |
Quality Assurance Program by  all  EPA Regional  Offices,  Program  Offices,
EPA Laboratories, and the States.   This  includes  those  monitoring  and        «
measurement efforts mandated  or supported  by EPA  through  regulations,        •
grants, contracts, or other formalized agreements.   The Quality Assurance    •
Programs for the States in Region V will be  cooperatively developed  with
them and implemented through  the Regional  Office.                            •

The Office of Research and Development (ORD) has  been given  the responsi-
bility for developing, coordinating, and directing the  implementation        M
of the Agency Quality Assurance Program.   In addition,  an Agency Quality     I
Assurance Advisory Committee, chaired  by ORD and  with representatives
from the Program Offices, Regional  Offices,  Staff Offices, and  the
States, has been established  to coordinate this effort.                      •

At this point, the distinction between two concepts  --  quality  assurance
and quality control -- becomes relevant.   "Quality Assurance" is defined     •
here as an organization's total  program  for  assuring the  reliability        •
of data it produces.  A QA Plan is a document  presenting  the policies,
objectives, management structure, and  general  procedures  which  comprise
this total program.  "Quality Control" refers  to  the detailed and            •
specific procedures used to ensure the quality of data  produced by a        •
particular measurement activity.   For  example, a  QA  Plan  for laboratory
instruments would state that  calibration needs to be addressed  as  an        •
element of data collection activities.  It would  not, however,  give          |
instructions about how to do  this calibration; these instructions
represent quality control.                                                  —

As an initial  step in implementing this  policy, Quality Assurance            •
Plans (Programs) must be prepared by all EPA-supported  or -required
environmental  monitoring and  measurement activities  per the  specifications   •
of EPA's guidance document MQA 001-79.                                      |

EPA policy is quite clear that the Agency  Quality Assurance  Program          _
encompasses all environmentally related  measurement  activities  undertaken    •
by the Regional Offices, Program Offices,  State Program Offices, and        ™
Laboratories; supported by these divisions through contracts, grants,
or other formalized agreements; or required  by them  through  regulations.     •
A very broad definition of "environmentally  related  measurement             I
activities" has been adopted.  It includes all field and  laboratory
investigations which generate data. The measurement of chemical,            •
physical or biological parameters in the environment; health and            •
ecological effects studies; clinical and epidemiologic  investigations;
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    studies involving laboratory measurements  or simulated  environmental
    events are covered under this definition and all  such activities  must
    be covered by a Quality Assurance Plan.

    This document describes the Quality Assurance Program for Region  V,
    U.S. EPA, that will  produce a numerical  estimate  of the reliability  of
    all data values reported or used by the  Region.

2.  QUALITY ASSURANCE POLICY STATEMENT. REGION V

    It is the policy of EPA, Region V that there shall  be sufficient
    quality assurance activities conducted within the Region to  assure
    the collection of data which meet the requirements  of the Environmental
    laws and regulations that require implementation  by EPA in Region V.

    The Regional  Administrator has the overall responsibility for
    implemenation of the Agency's quality assurance program for  valid
    data quality.  The Director of the Surveillance and Analysis
    Division (S&A), through the Chief of the Quality  Assurance Office
    (CQAO), assures that quality assurance objectives are met for each
    monitoring project conducted within Region V. This responsibility
    also includes external monitoring activities of States, local
    agencies, contractors and others covered by the Agency  quality
    assurance plan.

    The immediate objective of the Quality Assurance  Office is to insure
    that the quality of data collected, reported or used by the  Agency
    is properly documented and that the data are sufficiently accurate
    and precise to meet the Agency's quality assurance  objectives.

    The following activities shall be carried  out in  accordance  with
    Agency mandates specified in document MQA  001-79, and existing
    Agency regulations.

         The Quality Assurance Program will  consist of:
              1.   An adequately trained staff  for implementation of the
                  Region's quality assurance program  as approved by ORD.

              2.   Equipment procurement and  maintenance shall  meet
                  specifications required by regulations, approved
                  methodology, or appropriate  EPA guidelines and shall
                  be approved by the CQAO.   These requirements shall
                  appply to all  Region V monitoring activities and to
                  State and local  agencies when Federal  funds  are
                  expended.

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3.  Analytical  methods and procedures for all  monitoring          p
    programs shall  conform to EPA approved methodology
    when applicable, and shall include quality control            H
    measures.   All  methods and procedures shall  be                •
    documented  "cookbook fashion" and reviewed and approved       •
    or revised  as required by Agency regulations and
    guidelines.  Their revisions and updates shall be             •
    by the appropriate Agency mechanism, based on                 |
    recommendations from the CQAO.

4.  The Regional  Administrator, based upon recommendations        I
    from the CQAO,  through the Director, Surveillance and         m
    Analysis Division, shall approve State and local agency
    Quality Assurance policies and programs.                      •

5.  Region V and State and local laboratory and field
    monitoring  facilities shall perform system and                •
    performance audits.  These facilities shall  participate       •
    in inter!aboratory audits managed by the AQAC and
    coordinated with EMSL-RTP, EMSL-Cincinnati and EMSL-Las Vegas-.

6.  Data processing shall be documented, reviewed and             •
    revised as  required by the Region's Quality Assurance
    Program and approved by the Office of Research and            •
    Development.   Quality control measures must assure            gj
    accurate data from analysis by Region V, State and
    local agencies.  Data shall be validated according            —
    to criteria which shall follow EPA guidelines and             I
    regulations.                                                   •

7.  Directors  of the several divisions in Region V have           •
    responsibilities for the quality of data collected            |
    and used in the performance of tasks required.  These
    responsibilities are corroborated under this policy.          •
    The CQAO will coordinate the implementation criteria          •
    for validation of required data.                              "

8.  Standard operating procedures for air monitoring              •
    activities in Region V, State and local agencies for          •
    site selection, audits, evaluations, maintenance and
    enforcement shall be developed, documented and                M
    reviewed per the requirements of 40 CFR Part 58.              •


9.  The CQAO shall  report continuously on all  Quality             •
    Assurance programs to program managers.
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   CONCURRErCE
                                    .                 .
                       Ctfief, Quality  Assurance "Office,
                       Surveillance &  Analysis Division,
                       Region V
                                               Date
   COfCURRENCE
   APPROVED
Director, Surveillance & Analysis
Di v>s~NDn, Jtegi on V
                                             /
                                                                   1  Date
                 w
 egional Administrator
Regjion V
                                                                      Date
3.  OBJECTIVES AND MILESTONES

    The primary goal  of the Region V,  quality assurance program is  to
    define and improve the reliability (accuracy  and precision)  of
    data generated and used by the Region,  per Headquarters'  mandate
    and Agency regulations.  There must be  a mechanism for so doing.
    In order to measure or estimate changes in data  quality,  the
    quality must be expressed in measurable (numerical) terms.   There-
    fore, the first priority in the Region  V quality assurance  program
    is to establish and implement a trethod  to define and quantitate
    the program product - data qualify.  This includes data from Regional
    programs, State and local agencies, grants and contracts.   Each
  -  program that collects data is to be quality assured by a  comprehensive
    evaluation and review process such that all of the activities that
    influence the quality of data are  performed by appropriated  trained
    staff, by methods acceptable to EPA on  instruments that are  approved
    and maintained and each data collection activity has a documented
    quality controlled program.

    MILESTONE 1:  Interim Region V Quality  Assurance Program  will be
    developed by the  QAO by January 15, 1980.   This  program will  be
    amended and updated to meet the Agency's final QA requirements  for
    1981 within 90 days after final guidance from Headquarters  becomes
    available.

    MILESTONE 2:  All Regional Program Offices that  are engaged  in  a
    field sample collection activity shall  prepare a field sampling
    and quality control manual which documents their methods  of  sample
    collection, preservation, field custody, field instrument calibrations
    and field quality control protocol, plus any  other requirements
    specified in Section 8 of this document, by April  15,  1980.   These
    documents will be submitted to the QAO  for review and  recommendations
    to the Regional Administrator for  approval  by Sampling programs

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Included are air, hazardous  waste,  toxic  substances,  priority  pollutants,     |
public water supply,  ambient surface and  ground  water,  NPDES and
Great Lakes.  Programs are to be updated  per the requirements  of             •
new Agency regulations or guidelines.                                         •

MILESTONE 3:  All Laboratories in the Surveillance  and  Analysis
Division engaged in analysis of samples shall  document  their                  •
methodology and quality assurance/control  program per the  specifications      I
in Section 8 of this  document, by April 15,  1980 and  submit such
documentation to the  QAO for review and recommendations to the Regional       •
Administrator for approval.   Programs are to be  updated per the               I
requirements of new Agency regulations or guidelines.                         m

MILESTONE 4:  All State's Water Agency(s)  shall  document their field         •
and laboratory methodology and quality assurance/conrol  program  per          |
the specifications in Section 8 of this document according to  the
dates specified in each State's 106 grant condition by  the Regional           •
Administrator.  These documents are to be forwarded to  the respective        I
State Coordinator for processing through  the media  manager and the           ™
S&A Division to the QAO for  review and recommendations  to  the
Regional Administrator for approval as required  by  Agency  regulations.        •

MILESTONE 5:  All State and  Local Air Agency(s)  shall document
their field and laboratory methodology and quality  assurance/control         •
program per the specifications in Section 8  of this document by               •
January 1, 1980 to the respective State Coordinator for processing           m
through the respective media managers and the S&A Division to  the
QAO for review and recommendations to the Regional  Administrator             •
for approval.                                                                I

OBJECTIVE:  Manage the quality assurance  functions  in Region V that          H
impacts all factors that influence data quality  in  the  Region's               I
FY 80 program plan.  The factors to be considered are personnel,
equipment, procurement, methodology, legal requirements, organizational
responsibilities where QA policies must be carried  out  and other             •
factors.  The implementation of an effective program  will  insure             I
objectivity, self review and documentation so that  cost effectiveness
in the program is assured.  Objectives have been identified for  each        •
program decision unit for FY 80, which are depicted in  Appendix  1.          I

MILESTONE 1:  Key action steps(milestones) have  been  finalized
with due dates for objectives listed under each  decision unit  for           •
FY 80, which is also depicted in Appendix 1.                                |

OBJECTIVE:  To establish an  interaction  at all  levels  of  management        •
such that QA principles ara  implemented.                                     •
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                                   7

    MILESTONE 1:   These interractions  are  in  place  and  are  illustrated
    in Appendix 2.

    OBJECTIVE:  To have QA resources  assigned to QAO in proportion  to
    need, rather than programs controlling resources by which  priorities
    in those programs preclude resource commitment  to QA as the program
    planning process specifies and the National  QA  program  mandates.

    MILESTONE 1:   During the planning  process for FY 81, the QAO will
    identify all  activities that have  QA requirements.   Assess resource
    needs for enumeration of those QA  activities.  Formulate FY 81  QAO
    Zero Based Budget activities with  QA committments.   This resource
    assessment will encompass implementation  of the Region's FY 81  QA
    plan (program) as approved by ORD.

4.  QUALITY ASSURANCE MANAGEMENT

    4.1  Introduction
         The current quality assurance program that is  functional  in
         Region V during FY 80 evolved from the program planning process
         and is carried out under restrictions which are placed on  QA
         by resource commitments and  priorities that are established
         by programs which provide those resources.  The organizational
         structure of Region V which  relates  to data collectors and
         decision making based on results  of  collected  data is shown
         in Appendix 3.

         A description of the Organization for present  QA related
         activities follows:

         WATER DIVISION: Has responsibilities in the public water supply,
         ambient surface and ground water and wastewater programs.
         The administration of these  programs through grants results
         in data collection by State  and local personnel.   Resources
         (Appendix 1) for quality assurance are provided through Decision
         Units B-224 (Ambient Water Quality Monitoring) and C-215
         (Public Water Supply Management).

         AIR AND HAZARDOUS MATERIALS  DIVISION:  Has responsibilities
         for air programs, hazard waste management, pesticide  and toxic
         substances.  Programs are managed through  grants and  contracts.
         Technical and field support  is provided by the S&A Division
         through activities of the District Offices, Technical Support
         Branch and the Central  Regional Laboratory. Resources for
         quality assurance are provided through Decision Units A-235
         (Air Quality Monitoring), A-305 (Air Enforcement), and A-305
         (Air Enforcement Unleaded Gas Inspections).

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     ENFORCEMENT DIVISION:   Has responsibilities for enforcement             I
     action in the various  programs  for compliance with Agency
     regulations.   QA  of data  collection is  important to the                 •
     validation of data  so  that it can be defended in legal processes.       •
     Resources are provided for QA in the A-305 Decision Unit for
     PSD monitoring.   However,  QA support is provided in the B-303
     Decision Unit by  the QAO  without resources being provided by            I
     the Enforcement Division.                                               •

     PLANNING AND MANAGEMENT DIVISION:  Maintains data processing            •
     facilities and handle  data for  special  studies and STORET.              |
     Although the data unit processes data collected by other
     organizations, it produces final'reports from data which                _
     may require summary or collation for final data reporting.              I
     Thus,  it is in the  overall  process, a data producer.  QA                •
     has no resource support for this division.  QA programs have
     not been employed.                                                      •

     S&A DIVISION: Is responsible for surveillance and analysis in
     the various water,  air, waste and toxic substance programs.             _
     Technical support,  monitoring and project studies are carried           •
     out for the program offices.  Resources for QA in these various         ™
     functions of the  S&A Division are those described under the
     other divisions.  S&A  Division  branches support QA programs by          •
     auditing, sample  collection, and special  studies.                       |

     GREAT LAKES NATIONAL PROGRAM OFFICE:  The Great Lakes are monitored     -
     under this program  through grants and contracts for sample              I
     collection and shore laboratory analysis, as well as, the
     operation of the  ship  for open  waters and shipboard analysis
     by contract.   Technical and field support is also provided by           •
     the S&A Division  through  activities of  the District Offices,            •
     Technical Support Branch  and the Central  Regional Laboratory.
     Resources for QA  is provided under Decision Unit B-241 (Great           •
     Lakes).                                                                |

4.2  Quality Assurance Management Plan
     In this context the implementation of a quality assurance               I
     program is deemed as a management endeavor which attempts to            •
     interface all activities  which  impact data quality, be they
     management, technology, statistics, monitoring or maintenance.          •
     In order to assure  the data quality, each of the numerous               |
     activities must  respond to the  basic needs from which data
     becomes possible.

     When one realizes that the simplest item may become a                   •
     critical item in  data  collection, it then becomes apparent
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       how the many disciplines  work  in  concert.   The  QA  program
       will not presume that certain  activities  occur.   It will require
       that documentations and controls  be  implemented and evaluated
       for effectiveness on a prescribed frequency basis.  These
       evaluations describe deficiencies and  corrective actions
       requi red.

       In the formulation of the QA plan for  Region V  the mandates
       for carrying out QA are documented in  the  Quality  Assurance
       Policy (Section 2).  In this policy, management has designated
       responsibilities and the  individual  who bear those responsibil-
       ities.  The organizational  structure into  which the QA management
       interacts  is established  by this  policy (Appendix  2).  Adminis-
       tratively, the QAO may be shown in a different  relationship.

4.2.1  Assignment of Responsibilities
       The Quality Assurance Office located in the Surveillance and
       Analysis Division has the responsibility  of managing Region
       V's quality assurance program.

       The Quality Assurance Office (QAO) establishes  policies
       and guidelines for regional, state and local quality assurance
       programs,  and conducts independent audits.   Quality control,
       i.e.,  quality and documentation of data used by regional/state/
       local  personnel, is the responsibility of the data generator.
       The mission of the QAO is to ensure  through implementation of the
       quality assurance program so that the  quality of data collected,
       reported or used by the Region is properly documented and that
       the data are sufficiently accurate and precise  to  meet Regional
       program needs.  The Quality Assurance  Office is responsible
       for developing and implementing procedures (programs) to
       insure the reliability of laboratory data  supporting the
       air, pesticides, solid waste and  toxic substances  programs
       in the Air and Hazardous  Materials Division, the public
       drinking water, ambient surface and  ground water,  and industrial
       and domestic wastewater programs  in  the Water Division;
       enforcement actions in the Enforcement Division; the Inter-
       national Joint Commission, the harbor  dredging  programs in
       the Great  Lakes National  Program  Office,  and all other programs
       generating environmental  data  for the  Region.

       QAO conducts annual on-site system evaluations.  The
       evaluations are of the quality assurance  and quality control
       programs of State laboratories and monitoring facilities that
       carry  out  testing under the Clean Air  Act,  Clean Water Act,

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Resource Conservation and Recovery Act,  Safe  Drinking  Water            |
Act and the Toxic Substances Control  Act.   In some  instances
local  agencies are evaluated where state responsibility  has            •
been delegated.  QAO identifies deficiencies, recommends               I
corrective action and monitors effectiveness  of action taken.

The QAO reviews state program  plans for  compliance  with  Agency          I
requirements for quality assurance and analytical methodology           •
used in laboratories and field operations.  The QAO coordinates
quality assurance programs with Agency regulations, program
guidance and media strategy.
                                                                       I
The on-going management  of the laboratory  certification  program,
pursuant to the Safe Drinking Water Act, is  the  responsibility          •
nf the OAfL  This function also involves continued  aualitv              •
of the QAO.  This function also involves continued quality
assurance activities for certified laboratories;  an overview
of state certification programs for certification of local
laboratories and the performance of State certification officers.
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The Quality Assurance Office manages an inter!aboratory audit          _
program which provides an extensive reference and quality              I
control sample program for cooperating Federal, Canadian,              *
State and local agencies, and private laboratories in Region V.

Approximately 123 laboratories participate in this program.             |
Up to 316 different parameters are analyzed on a  regular
basis.  The audits cover air, public water supply, ambient             •
water (large lakes included), wastewater, dredging (sediments)          I
and toxic pollutant laboratory analytical activity.   These
audits are extremely important for the determination of accuracy
of laboratory performance.  Results are evaluated and recommendations  •
made for corrective actions for any deficiencies  identified.           I

The management of the alternate test procedure program for             •
compliance with the Safe Drinking Water Act, National Pollution         I
Discharge Elimination System and other regulations,  is the
responsibility of the QAO.  This function includes technical
interepretation of the regulations relating to test  procedures,         I
coordination of applications, evaluation of applicants'  technical       •
data for equivalency and recommendations for approval or
disapproval.                                                           •

The QAO participates in quality assurance activities for
the International Joint Commission Water Quality  Board's               _
monitoring activities on the Great Lakes.  This  function includes       I
critical reviews of technical reports, maintenance of approved          •
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        analytical  methods  and  methods  under  consideration  for  approval,
        official  interpretations  of method  equivalency  for  regulatory
        actions and defends regional  data generated  by  approved procedures.

        The QAO is  responsible  for providing, as  requested,  review
        and technical  assistance  concerning Agency analytical methodology
        and quality assurance requirements  for State and  local  environmental
        agencies, NPOES dischargers,  public water supplies,  source
        emissions,  etc.  The QAO  interprets National  and  Regional EPA
        policies  in the areas of  analytical methodology and  quality
        assurance.

        The QAO is  responsible  for the  management of the  quality ,
        assurance requirements  for all  Region V external  projects
        involving collection and  analytical measurements, which includes,
        but is not  limited  to,  grants,  contracts, cooperative agreements,
        and interagency agreements.  The QAO's primary  function is to
        insure that all analytical measurements conducted with  Regional
        funding results in  usable data  of known quality that is acceptable
        for Region  V's purposes.   The air responsibility  includes
        maintenance ind primary calibration of field and  laboratory
        equipment re ative  to air pollutants  measurements,  and  step-by-step
        demonstrations of all facet*  of instrument maintenance, calibration
        and operation.

4.2.2.  Flow of Information
        The QAO is  assigned activities  under  decision units  which
        require evaluation  of data producing  systems.  The  S&A  Director
        establishes priorities  and delegates  resources  to the various
        tasks.  These tasks are identified  in the annual  work plan.
        The QAO identifies  goals  to accomplish the objectives of the
        decision units per  the  specification  from Headquarters  program
        guidance from the Regional media programs, (for example,  evaluation
        of QA programs for  air  monitoring in  State Agencies).   The QAO,
        through the S&A Director, establishes contact with  State Agenciei  and
        arranges for information  about  the  State's program  and  an on-site
        visit.  Information obtained  prior  to an  on-site  visit  is evaluated,
        the on-site evaluation  is performed and an evaluation report is
        prepared.  The evaluation is  reported through the S&A Director
        to the State, to the Regional Air Program Office  and the State
        Coordinators.  Corrective action, deficiencies  and  recommendations
        are reported.  States report  corrective action  taken or give
        reasons for not taking  action to the  QAO.  Should the
        corrective  action be of such  a  nature that an on-site
        visit is  required to verify that the  action  was appropriate.
        <\ visit is  requested through  the S3A  Director:  The  on-site visit

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       is reported in a  similar manner  to  the  original  evaluation  report        |
       stating the findings  and indicating satisfactory or  non-satisfactory
       results and recommending future  action  as  required.                      _

       When problems  exist in  which  no  correction is made and  a  dispute         ™
       results, the findings with recommendations are  reported to  the
       Program Office and to the State  Coordinators for resolution.             •
       If a State program is involved and  the  program  office is  unable          |
       to resolve the problem  and an impasse is  reached, the
       Regional Administrator  makes  a final determination of the               _
       unresolved issue  based  on recommendations  from  the QAO  and               •
       program office.   Basically two major types of reports are               ™
       generated by the  QAO.  They are  accuracy  and performance  audits
       and on-site system evaluation reports.  The content  of  these             •
       reports are outlined  in Section  8.7.2 and  Subsection 8.7.2.1             |
       of this document.

       Based on the frequency  identified in the QAO program plan               •
       (Section 12),  the QAO will write interpretative reports to               *
       management. These reports will  be  made on a regular basis
       and will identify areas of work  that could be improved  and               •
       areas that are being  performed properly or in an exceptional             |
       manner.  These reports  will be based on information  obtained
       during on-site evaluations, from reviews  of performance sample           _
       analyses and from evaluations of routine  quality control                 I
       audit data.                                                             ™

4.2.3  Identification of QA  -  Related Committees  or Meetings                    •
       Quality assurance requirements/information are  transmitted               |
       within Region  V through meetings called by the  QAO with affected
       Regional media personnel.  These are on an as needed basis.              m
       Documentation  is  also provided by way of memoranda.                      •

       Quality assurance requirements/information are  transmitted
       to State and local agency laboratory directors  and quality               •
       assurance coordinators  by written communcations from the  Quality         |
       Quality Assurance Office on  a as needed  basis.   QA  information
       is also disseminated  through  the audit  and on-site evaluation of         _
       Regional, State and  local agency monitoring activities  during            •
       the frequencies specified in  the QAO's  FY  80 program plan               •
       (Appendix 1).

       The QAO will conduct  two workshops  in FY 80 for.public  water             |
       supply analysts.   The workshops  will be for standardizing metal
       analyses and for  upgrading organic  analyses for public  water
       supply laboratories.   The Central Regional Laboratory will               I
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       provide technical  support  to  the  QAO  in  this  endeavor by making
       their laboratory facilities available and  having  their  personnel
       participate in the workshops.

       The QAO has identified State  and  local air program  agencies
       that are in need of technical  assistance in the area of quality
       assurance and laboratory capability.   Through a contract that
       EMSL-RTP has in place, the QAO will work with the contractor
       to upgrade those agencies  that are  in need of technical assistance.
       This activity will commence the 2nd quarter of FY 80.

       A workshop for audits of air  monitoring  sites will  be conducted
       by QAO and RTP at Region V in March 1980 for  Region, State
       and local agency personnel engaged  in auditing air  monitoring
       sites.

       The Quality Assurance Office  participates  in  the  Agency's
       regularly scheduled semi-annual QA  coordinator's  meeting where
       the Agency's QC concerns are  addressed.  The  QAO  participates in
       national short term QA tasks  as requested  by  the  National Program.

       The Chief, QAO has been appointed to  the Data Quality Work
       Group, Surveillance Sub-Committee,  International  Joint  Commission,
       Water Quality Board.  The  Data Quality Work Group has the
       responsibility of assuring the quality of  data from participating
       laboratories engaged in the Surveillance Sub-Committee's Great
       Lakes Surveillance Plan.  All  IX QA  activities are implemented
       through the Data Quality Work Group.   The  Work Group meets
       monthly.

4.2.4  Description of Needs
       The following resources are required  to  accomplish  the  QA
       objectives and milestones  identified  in  the interim QA  program
       for Region V.

       A.   Staff - Twelve man years of  effort  is required to  fully
            implement the Quality Assurance  Program  for  Region V.
            Sixty-six (66) percent of staff  is  in place.   Present
            staff consist of the  Office Chief,  1  secretary, 2  professional
            chemists, 1 professional  microbiologist, 1 professional
            physical scientist, 1 journeyman organic chemist and
            1 journeyman electronics technician.   Professional organic
            chemistry support is  provided  to the  QAO on  an as  needed
            basis from the CRL (this support will  continue for the
            "hands on" experience).   The type of  additional staff
            required (34%) is 1 professional  organic chemist,  1
            statistician (or chemist with  a  good  statistical background)
            and 2 journeyman inorganic chemists.

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              Monetary  -  The  QAO  needs approximately $120,000 for                 •
              contracts.   These contracts are to be used to develop
              software  EDP capability for measurement methods and                 •
              statistical  data evaluation for minimum turn around                 Jj
              time.   Data quality problems could be identified much
              faster and  larger volumes  of data can be evaluated.
              Time - If all resources identified in Section 4.2.4  are             I
              granted the QAO, the program described in this document             •
              could be  fully  implemented in 90 days after receipt  of
              resources.                                                          •

              Training  Seminars - The QAO is providing workshops for
              standardizing metal analyses and upgrading organic                  _
              analyses  performance for Region V and State laboratory              •
              personnel during the second quarter of FY 80-.  A workshop           •
              for audits  of air monitoring sites will also be provided
              Region V, State and local  agency personnel.  Travel  funds           •
              will be required to get personnel to these workshops               I
              when their  agency can not  afford to send them.
              Approximately $2,000 is required for this travel.
    Key personnel  of the Quality  Assurance  Office must have  sufficient           •
    administrative and technical  stature  to be  considered  a  peer  to              I
    the Managers of monitoring  activities within the Region  and to the
    Managers of Region V State  and local  laboratories.  This  staff
    must have a professional  knowledge/training and understanding of             I
    chemical/microbiological  principles,  concepts, practices,  established        I
    methodology and measurement (instruments) systems.  The  individual
    must have at least two  years  of bench experience in his/her speciality,      •
    particularly in an environmental  laboratory.  The individual  must            •
    have experience in developing and implementing intralaboratory
    quality control programs.   Regional QAO personnel must have knowledge
    of Federal laws, Agency regulations and guidelines pertaining to             I
    quality assurance and analytical  procedures related to the Agency's          I
    regulatory monitoring programs.   The  individual must be  experienced
    in meeting and dealing  with Regional, State and local  government             •
    officials and other Federal Agencies.                                       •
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Analytical operations in the laboratory can be graded according
to the degree of complexity.  Some analyses require no sample
treatment, and the measurement can be performed in minutes  on a
simple instrument.  Other determinations require extensive  sample
preparation prior to complex instrumental  examination.  Consequently,
work assignments in the laboratory should be clearly defined.
Each analyst should be completely trained and should fully  understand
all the assignments of his job before being given new responsibilities.
In this regard, all analysts, subprofessional or professional, should
be thoroughly instructed in basic laboratory operations,  according
to the extent of professional maturity.  Some of the basic  operations
that will be reviewed with laboratory personnel during the  on-site
evaluation follow.

a.   SAMPLE LOGGING: Routine procedure for recording of samples
     entering the laboratory and assigning primary responsibility
     should be emphsized.  The information that is required and  the
     routing of the samples to the analyst is then established.  The
     stability, preservation, and storage of samples prior  to
     analyses are then discussed.

b.   SAMPLE HANDLING:  The analyst should understand thoroughly  at
     which points in his procedures the sample is to be settled,
     agiated, pipetted, etc., before he removes it from the original
     contai ner.

c.   MEASURING:  The analysts, especially new employees and sub-
     professionals, should be instructed in the use of volumetric
     glassware.  The correct use of pipettes and graduates  should be
     emphasized.

d.   WEIGHING:  Because alsmost every measuring operation in the
     analytical laboratory is ultimately related to a weighing
     operation, the proper use of the analytical  balance  should  be
     strongly emphasized.  Maintenance of the balance, including
     periodic standardization, should be repeatedly emphasized to
     all personnel.

e.   GLASSWARE:  All glassware should be washed and rinsed  according
     to the requirements of the analysis to be performed.   Not only
     must the personnel assigned to these tasks be instructed, but
     also all lab personnel should know the routine for washing  and
     special  requirements for particular uses of glassware.   In
     addition, the precision tools of the the laboratory  such as

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pi pets, burets,  graduates,  and tubes  should  be inspected  before         •
use for cleanliness,  broken delivery  tips, and clarity  of
marking.  Defective glassware should  be  discarded  or segregated.        •

INSTRUMENTATION:   Operation and maintenance  of analytical
instrumentation  is of primary consideration  in the production
of valid data.   All instruments must  meet the requirements              I
specified in Agency regulations, be properly calibrated,                •
quality-control  checks documented,  and standard curves  verified
on a routine basis.  References on  instrumental  quality control
are presented in Section 8.4 and 8.5  of  this document.
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DATA HANDLING AND REPORTING:   As with  sample logging,  the routine      —
procedure for recording results of analyses and pertinent              •
observations, including quality control  checks, should be              •
emphasized.  Analytical data  should be permanently recorded in
meaningful, exact terms and reported in  a form that permits            •
future interpretation and unlimited use.   Details  are  discussed        |
in Section 9 of this document.

QUALITY CONTROL: The need to  continuously assess precision and          I
recovery values of methodology is a prime responsibility of the        —
analyst.  Self-evaluation through the  analyses of  QC samples,
replicates and recovery of spikes from samples representative           •
of the daily workload provides confidence and documentation            •
of the quality of the reported data.

SAFETY:  Laboratory safety should be discussed on  a continuing          I
basis with all employees, but it should  be emphasized  when an
employee is assigned to perform new duties.

IMPROVEMENT:  In summary, quality control begins with  basic            •
laboratory techniques.  Individual operator error  and  laboratory
error can be minimized if approved techniques are  consistently          •
practiced.  To insure the continued use  of good technique, lab-        g
oratory supervisors should periodically  review the basic techniques
and point out areas of needed improvement with each analyst.            _

Continuing improvement of technical competence by  all  laboratory       •
personnel is, of course, the  final responsibility  of the
laboratory supervisor.  In a  well-organized laboratory, however,       •
a big-brother attitude of higher ranking to lower  grade personnel      |
should be encouraged; each person should be eager  to share
experience, tricks of the trade, special  skills, and special            _
knowledge with subordinates.   Obviously,  efficiency and results        •
will improve.                                                          ™
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    k.    SKILLS:   The cost  of data  production  in  the  analytical  lab-
         oratory  is  based largely upon  two  factors: the  pay  scale  of the
         analyst,  and the number of data  units produced  per  unit of time.
         However,  because of the large  variety of factors involved,
         estimates of the number of measurements  that  can be made  per
         unit of  time are difficult.   If  the analyst  is  pushed to  produce
         data at  a rate beyond his  capabilities,  unreliable  results may
         be produced.  On the other hand, the  analyst  should be  under
         some compulsion to produce a minimum  number  of  measurements per
         unit of  time, lest the cost of data production  become prohibitive.
         In table 5-1, estimates are given  for the number of determinations
         that an  analyst should be  expected to perform on a  routine basis.
         The degree of skill  required for reliable performance is  also
         indicated.

         The time limits presented  in the table are based on use of
         approved methodology.   A tacit assumption has been  made that
         multiple analytical  units  are  available  for  measurements  requiring
         special  equipment, as for  cyanides, phenols,  ammonia, nitrogen,
         and COD.   For some of the  simple instrumental or simple volumetric
         measurements, it is assumed that other operations such  as
         filtration, dilution,  or duplicate readings  are required; in such
         cases the number of measurements performed per  day  may  appear
         to be fewer than one would normally anticipate.

6.  F/CILITIES. EQUIPMENT.  AND SERVICES

    The QA program makes Facilities, Equipment and Services  a major
    component of  the program.  The  recognition is made that  no data
    can be collected without the appropriate equipment that  is functional.
    To assure the operation of that equipment  all  facilities, equipment
    and services  must work  as a composite in a smooth  orderly manner.
    The items that are necessary are:

    A.   Laboratory facilties, building, utilities, equipment and maintenance.

    B.   Field facilities, housing for equipment,  transportation  require-
        ments, utilities, supplies, communications and maintenance.

    C.   Analtytical  equipment,  required methods,  operation and calibration
        manuals,  maintenance, parts and supplies.

    D.   Procurement  procedures, that require purchase  of the required
        equipment  with warrantees,  demonstrated satisfactory performance
        prior to  payment, service arrangements, availability of  spare
        parts, evaluation of equipment  from information  of prior users,
        costs evaluation and  comparisons  against  competitive equipment.

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1
TABLE 5-1


SKILL-TIME RATING OF STANDARD ANALYTICAL OPERATIONS

Measurement
Simple Instrumental:
-pH
~" Conductivity
'"'Turbidity
Color
~~Dissolved Oxygen (Probe)
Fluoride (Probe)
Simple Volumetric:
— Alkalinity (Potentiometric)
Acidity (Potentiometric)
Chloride
Hardness
— Dissolved Oxygen (Winkler)
Simple Gravimetric:
Solids, Suspended
Solids, Dissolved
Solids, Total
Solids, Volatile
Simple Colori metric:
Nitrate N (Manual)
Nitrate N (Manual)
Sulfate (Turbidimetric)
Silica
Arsenic
Complex, Volumetric, or Colorimetric:
BOD
COD
TKN
Ammoni a
Phosphorus, Total
Phenol (Distillation Included)
Oil and Grease
Fluoride (Distillation Included)
Cyanide
Special Instrumental:
TOC
Metals (by AA), No Preliminary Treatment
Metals (by AA) , With Preliminary Treatment
Organics (by GC), Pesticides, Without Cleanup
Organics (by GC), Pesticides, With Cleanup
iSki 11 -required rating numbers are defined as foil
1 - aide who is a semiskilled subprofessional
comparable to GS-3 through GS-5.
Skill Required
(Rating No.)1

1
1
1
1
1,2
1,2

1
1
1
1
1,2

1,2
1,2
1,2
1,2

2
2
2
2
2,3

2,3
2,3
2,3
2,3
2,3
2,3
2,3
2,3
2,3

2,3
2,3
2,3
3,4
3,4
ows:
with minimum background

2 - aide with special training or professional with minimum training
in general laboratory techniques and some
GS-5 through GS-7.
3 - experienced analyst capable of following
knowledge of chemistry,

complex procedures with
Number
Per Day

100-125
100-125
75-100
60-75
100-125
100-125

50-75
50-75
100-125
100-125
75-100

20-25
20-25
25-30
25-30

75-100
40-50
70-80
70-80
20-30

215-20
25-30
25-30
25-30
50-60
20-30
15-20
25-30
8-10

75-100
150
60-80
3-5
2-4

or training.

with background
comparable to

good background
in analytical techniques, professional, comparable to GS-9 through GS-12.
4 - experienced analyst specialized in highly
oo + A comparable to GS-11 through GS-13.
ZRate depends on type of samples.

complex procedures, professional,





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    E.    Preventive  Maintenance  policies  and  procedures.                         |

    F.    Service  and Repair procedures.                                          _

    G.    Audit  and Evaluation  requirements.

    H.    Safety.                                                                 •
         A protocol  for procurement testing is described in Appendix 4           I
         which  establish guidelines for equipment that are based on
         EPA guidelines, good  laboratory  practices and pertinent information     •
         from industries and governmental agencies where similar concerns        I
         are part of the art of  good management and quality assurance.
         As with  other operations,  the effectiveness of facilities are
         determined  by independent  evaluations.                                  •

7.  REVIEW OF PROGRAM PLANS. PROJECT PLANS. OR STUDY PLANS

    As  a statement of policy,  the QA program  requires a review of all            |
    program project  and study  plans for Region V, including the S&A
    Division study plans.   It  is essential that these plans are evaluated        —
    from the beginning so that the  appropriate measurement method is             •
    selected that will produce the  data the user needs.  Many, if not            •
    all, projects require data that lead  to decisions that have an
    economic impact  as well  as technologic impact.  The prevention of            •
    loss in monies,  resources  and time weighs heavily upon the plans             |
    that lead to  program or project development.  If those plans incorporate
    unapproved, and  inappropriate methodology which in turn produce              _
    data that are not pertinent  to  the program or project or do not              •
    have acceptable  precision, accuracy,  representiveness or completeness,       ™
    then the efforts are lost, lead to wrong  decisions, or cause equivocation.

    Since the review of plans  has not been customary in the past, it             |
    will be necessary to develop programs that accomplish this preliminary
    review process.   The various divisions and program units and QA              •
    must work together to initiate  this process as a Standard Operating          I
    Procedure.   The  details that need to  be accomplished are:

    A.    Directives  to Program,  Project or study offices requiring QA            •
         review of scope and plans  at the earliest data of the planning          •
         process.
    B.   Request of QA review requirements  must  be  in  writing.   This
         request should give some estimate  of the magnitude  of  study.
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C.   QAO, immediately upon initiation of the review process, would:
      1.  determine expertise required
      2.  technology

D.   Having established plans for review, the QA review would proceed
     and results would be reported.  The evaluation would declare
     feasibility with respect to provisions that assure the appropriate
     methodology, precision, accuracy, representativeness and completeness.
     Should factors be inappropriate or deficient, corrective measures
     would be stated to the project officer.

The Agency's protocol for evaluation of QA plans in extramural
projects and contracts will be used as soon as the document is
available.

QAO will investigate the needs for developing guidelines which
would be used to evaluate statistical, modeling, and other aspects
of environmental studies.  The location of expertise and at times
technology for unusual projects will require national concern.  Thus
these.needs will be formulated as they become appropriate.

A review of programs, projects or study plans would determine what
QA plans are to be incorporated in those plans.  The various activities
and items that must be identified are:

     o Staffing (personnel in numbers, qua!ifiication and training).

     o Methods (EPA approved methods must be used where required).
       Procedures must be documented and made available for review
       prior to use.

     o Quality control measures must be described in detail.
       This would explain the frequency of duplicate, spike or
       performance samples.  Control measures used in sample
       collection, with frequency of duplicate sampling prescribed.
       Audits by inter!aboratory, peer group, systems audits and
       performance audit must be described as to frequency and source
       of audit.  Control limits must be determined and the
       required measures that must be taken when out of control
       limits have been exceeded should be described.

     o Sample collection and preservation should be described
       in detail.  The calibrations of analytic methods and
       equipment must be according to the requirements of the
       approved methods.  Standards used for calibrations must
       be of the highest purity and referenced to MBS standards
       whenever possible.  Calibration procedures and tracability
       must be documented.

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    The QA plans must  appear  early  in the  planning process because
    without these QAO  will  not  have suitable information to move forward
    in the evaluation  process.                                                   .

    Suitable procedural  information for  developing QA plans based on             *
    the items discussed  above are available in the references cited
    in Section 14 of this  document.                                              •

8.  DATA COLLECTION

    Data quality changes occuring during data collection can come                I
    from six major activities:  a) formulating sound objectives for the
    sampling program,  b) collecting representative samples, c) maintaining
    sample integrity through  proper sample handling and preservation,            •
    d) adhering to appropriate  sample identification and, where needed,          •
    chain of custody procedures, e)  practicing quality assurance pro-
    cedures in the sample  transportation,  storage, and preparation               •
    processes, and f)  using proper  analytical techniques complete with           |
    appropriate quality  control activities to generate the actual data.

    8.1  Sampling Plan                                                          I
         The objectives  of the  sampling  program  affect all the                   •
         other aspects of  the sampling program.   Sampling program objectives
         are determined  by the  following activities: (a) planning (areawide      •
         or basin), (b)  permits,  (c) compliance,  (d) enforcement, (e) design,    |
         (f) process control, and (g) research and development.  The types
         of sampling programs to be employed, depending on suitability to        g
         program objectives,  include reconnaissance surveys, point- source        •
         characterization, intensive surveys; fixed- station- network monitoring,  ™
         ground-water  monitoring, ambient  air monitoring and stationary
         source emission monitoring, and special  surveys involving chemical,     I
         biological, microbiological, and  radiological monitoring.               •

         Factors that  must be considered in meeting the objectives of            m
         the sampling  program are the extent of  the manpower resources, the      •
         complexity of the parameters of interest, the duration of the survey,
         the number of samples, the frequency of sampling, the type of
         samples (grab or  composite), and  the method of sample collection        I
         (manual or automatic).                                                 I
          The media activity will  identify  the  need  for a  sampling activity
          in Region V.   A person with  lead  responsibility  in the media  activity
          is also identified to coordinate  the  project for the media  activity.
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      The identified need  is  transmitted  to  the  S&A Division.  The
      Technical  Support  Branch  coordinates the formulation of
      objectives and goals for  the  sampling  activity with the
      Central  Regional  Laboratory and  the appropriate District Office.
      Once goals have been formulated  to  accomplish objectives
      (including the six major  activities listed under 8 above),
      the proposal  is then reviewed by the QAO to  insure that all
      quality assurance  requirements for  producing valid data have
      been included.  If any  QA changes are  needed, the QAO will
      specify the changes  needed.   Once the  QA changes are made
      (if need be), the  QAO will concur.  The S&A  Division Director
      will transmit the  study proposal  to the Director of the
      requesting media program  for  review and see  if the defined objectives
      and goals meets the  program needs.  If not,  revision will be made
      (NOTE - QA is not  to be compromised).  Once  the Director of the media
      program concurs in the  proposal, the appropriate S&A Division
      Office/Branch or other  Divisions will  initiate the proposal.

8.2  Sampling Methodology
     The objective of sampling  is to obtain  a representative
     portion of the total  environment  under  investigation.  The
     sampling plan shall contain, as a minimum,  the following
     factors for concurrence  by the QAO (Item 8.1  above) in formulation
     of the sampling plan.

     A.  Water and Wastewater

          o Site Selection

          The location of  the sampling site  is critical in obtaining
          representative data.   Preferably,  water  sampling sites for
          point sources  of pollution from municipal and industrial
          effluents are  located at  points of highly turbulent flow
          to insure good mixing; however, inaccessibility, lack of
          site security, or power unavailability may preclude use
          of the best sites,  but these impediments should not be
          used as reasons  for collecting  samples at unacceptable
          locations.  Loctions  of sampling sites for streams,
          lakes, impoundments,  estuaries, and coastal areas vary,
          but in general occur  in the  following  bodies: (a) in
          water bodies for sensitive uses (swimming and drinking water
          supply),  (b)  in  major impoundments or  reservoirs near the mouths
          of major tributaries  and  in  the rivers entering and leaving the

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impoundments, (c)  in water bodies  polluted  by  man's  activities,    |
(d) in rivers upstream and downstream  from  tributaries,  and
(e) where hydrological conditions  change  significantly.            _

o Sample Type                                                     •

The basic types of water and wastewater methods  are  grab          •
sampling and composite sampling.   Composite sampling may be        I
conducted manually or automatically.   The six  methods
for forming composite samples,  all of  which depend on             •
either a continuous or periodic sampling  mode, are the             I
following: (a) constant sample  pumping rates,  (b)  sample
pumping rates proportional to stream flow rates, (c) constant
sample volumes and constant time intervals  between samples,        •
(d) constant sample volumes and time intervals between  samples     •
proportional to stream flow rates, (e)  constant  time intervals
between samples and sample volumes proportional  to total  stream    •
flow volumes since last sample, and (f) constant time intervals    |
between samples, and sample volumes proportional  to  total  stream
flow rates at time of sampling. The choice of using the grab
sampling method or one of the six  compositing  sampling  methods is  •
determined by program objectives and the  parameters  to  be sampled. B

o Use of Automatic Samplers                                       •

The use of automatic samplers eliminates  errors  caused
by the human element in manual  sampling,  reduces personnel         _
cost, provides more frequent sampling  than  practical for          I
manual sampling, and eliminates the performance  of routine        •
takes by personnel.  Criteria for  brand selection of
automatic samplers include evaluations of the  intake              •
device, intake pumping rates, sample transport lines,             |
sample gathering systems (including pumps and  scoops),  power
supplies and power controls, sample storage systems, and          •
additional desirable features to fit particular  sampling          I
conditions.  There are many comrnerically  available automatic
samplers; however, because no single automatic sampler
is ideally suited for all situations,  the user should             •
carefully select the automatic  sampler most suited for             |
the particular water or wastewater to  be  characterized.
Precautions must be taken in regard to using certain              m
types of samples in potentially explosive atmospheres.             I
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o Flow Measurements

An essential  part of any water or wastewater sampling
survey as well  as a necessary requirement of the National
Pollution Discharge Elimination System (NPDES)  permit
program is accurate flow measurements.  Flow measurement
data may be instantaneous or continuous.

For continuous  measurements, a typical system consists
of primary devices such as weirs and flumes and secondary
devises such as flow sensors, transmitting equipment,
recorders, and  totalizers.  The improper installation
or design of a  primary device or malfunction of any part
of a secondary  device results in erroneous flow data.
The accuracy of flow measurement data also varies widely,
depending principally on the accuracy of the primary
device and the  particular flow measurement method used.
In any case, measurements should be within +IQ  percent
of the true values.

As part of a monitoring activities'  QA program, a written
step-by-step procedure for the use of each type of flow
equipment employed by the monitoring activity shall  be
available.  The write-up is to include the protocol  for
installation of the measuring device (if appropriate),
maintenance and verifiction of calibration of the measuring
device in the field.  Documentation must also be maintained.
All mechanical  and electronic type current meters'  calibration
are to be traceable through an unbroken chain (supported
by documentation to some untimate or national reference
standard (i.e., NBS or NOAA).

o Statistical Approach to Sampling

Four factors must be established for every sampling program:
(a) number of samples, (b) frequency of sampling, (c) parameters
to be measured, and (d) sampling locations.   These factors
are usually determined in varying degrees by details of
the pertinent discharge permits or are more arbitrarily
set by the program resource limitations.   Nevertheless,
the nature of the statistical methods selected  and scientific
judgment should be used to establish the best procedures.

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     o Special  Sampling Procedures                                      I

       Special  sampling procedures  should  be  employed  for               •
       hazardous wastes, toxics,  municipal, industrial,  and             I
       agricultural  waters, and  surface  waters  as  well as
       bottom sediments and sludges,  and for  biological,
       microbiological, and radiological studies.                       •

B.   Air
o Sampling Site Selection Considerations
                                                                       I

     The need for an air quality monitoring  program  usually
     is related to one or more of the  following  objectives:             I

     1.  To judge compliance with and/or progress made  toward
         meeting ambient air quality standards.                         •

     2.  To activate emergency control  procedures that  prevent
         or alleviate air pollution episodes.                           _

     3.  To observe pollution trends throughout  a region,               •
         including nonurban areas.

     4.  To provide a data base for research evaluation of              |
         effects; urban, "land use, and  transportation planning;
         development and evaluation of abatement strategies;            •
         and development and validation of diffusion models.            •
     Sampling site and equipment requirements  are  generally
     divided into three categories,  consistent with  desired             •
     averaging times:                                                   •

     1.  Continuous—Pollutant concentrations  determined  with           •
         automated methods and recorded or displayed continuously.      I

     2.  Intermittent—Pollutant concentrations determined with
         manual or automated methods from ii
         daily samples on  a fixed schedule.
    manual or automated methods  from integrated  hourly or         I
     3.  Static—Pollutant estimates or effects determined from        •
         longer-term (weekly or monthly)  exposure of qualitative       |
         measurement devices or materials.

     Air quality monitoring sites that employ automatic equip-          I
     ment to continually sample and analyze pollutant levels            ™
     may be classified as primary.  Primary monitoring stations
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are generally located in areas where pollutant  concentrations
are expected to be among the highest and in the areas  of
highest population density and, as such, are often employed
in health effects research networks.  In addition, these
stations are designed as a part of the air pollution
episode warning system.

o Network Design Considerations

In designing an air quality monitoring activity, the
following four criteria for locating sites should be
considered, either singly or in combination, depending
upon the objective of sampling:

1.  Orient monitoring sites to measure the impacts of
    known pollutant emission categories on air  quality.

2.  Orient monitoring sites relative to population
    density to measure receptor-dose levels, both short
    and long-term.

3.  Orient monitoring sites to measure the impacts of
    known pollutant emission sources (area and  point)  on
    air quality.

4.  Orient monitoring sites to obtain measurements
    representative of areawide air quality.

In order to select locations according to these criteria,
it is necessary to have detailed information of the location
of sources of emission, the geographical variability of
ambient pollutant concentrations, meteorological conditions,
and population density.

o Representative Sampling

Assuring the collection of a representative air quality  sample
depends on the following factors:

1.  Locating the sampling site and determining  network size
    consistent with monitoring objectives.

2.  Restraints on the sampling site imposed by  meteorology.

3.   Restraints on the sampling site imposed by local  topography,
     emission sources, and physical  constraints.

4.   Sampling schedules consistent with monitoring objectives.

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                                            26

                       o Locate Sampling  Site and  Determine Network Size

                       Consistent  with  monitoring  objectives  previously noted,
                       networks are designed to  meet  at  least one of four major
                       objectives.   The following  tabulation  presents examples
                       of currently implemented  networks  applicable to each of
                       these "objectives"  categories:
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     Objective
       Network
     Comment
Compliance
monitoring
Emergency
episode monitoring
Trend monitoring
Research
monitoring
SIP (State Imple-
mentation Plan)
SIP/1ocal agency
emergency control
program
NASN (National
Air Sampling
Networks)

CHAMP (Community
Health Air Monitor-
ing Program)
To demonstrate attainment
or maintenance of Air
Quality Standards

To activate immediate,
short-term, emission
controls for prevention
of episodes

To fulfull  mandate of
Federal legislation
To determine long-term
pollutant trend in
selected areas with
respect to health effects
                       o Compliance Monitoring

                       The information required  for selecting  sampler  location is
                       essentially the same as that for  determining the  number of
                       samplers, i.e., isopleth  maps,  population  density maps,
                       and source locations.  Following  are  suggested  guidelines:

                       1.  The priority area  is  the zone of  highest pollutant
                           concentration within  the region.  One  or more stations
                           are to be located  in  this area.

                       2.  Close attention should  be given to  densely  populated  areas
                           within the region,-especially when  they are in the vicinity
                           of heavy pollution.
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                          6.  Some information of air quality should be  available  to
I                            represent all  portions of the regions.

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3.  For assessing the quality of air entering  the  region,
    stations must also be situated on the  periphery  of  the
    region.  Meteorological  fetors such  as frequencies
    of wind direction are of primary importance  in locating
    these stations.

4.  For determining  the effects of future  development on the
    environment, sampling should be undertaken in  areas of
    projected growth.

5.  A major objective of surveillance is evaluation  of  progress
    made in attaining the desired air quality.   For  this purpose,
    sampling stations should be strategically  situated
    to facilitate evaluation of the implemented  control
    tactics.
Some stations will  be capable of fulfilling  more  than  one  of
the functions indicated; e.g., a station located  in  a  densely
populated area can  indicate population exposures  and also  document
the changes in pollutant concentrations resulting from control
strategies employed in the area.

o Emergency Episode Monitoring

For episode avoidance purposes, data are needed quickly--
in no less than a few hours after the sensor is contacted
by the pollutant.  While it is possible to obtain data
rapidly by on-site  manual  data reduction and telephone
reporting, there is a trend toward automated monitoring
networks.  Obviously, the severity of the problem, size
of the receptor area, and availability of resources  influence
both the scope and  sophistication of the system.

It is necessary to  utilize continuous air samplers because
an episode lasts only a few days and the control  actions
taken must be based on "real-time" measurements correlated
with the decision criteria.  Based on alert  criteria now
in use, 1-hour averaging times are adequate  for surveillance
of episode conditions.   Shorter averaging times provide
information on data collecting excursions but increase
the need for automation because of the bulk  of the data
obtained.  Averaging times longer than six hours  are not
desirable because of the delay in response this imposes.

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Collection and analysis must be accomplished rapidly if the       •
data are to be useful immediately.   There is no time to
check out the methods, run blanks,  calibrate,  etc.,                •
after the onset of episode conditions.   In order for the          |
instrument to be maintained in peak operating  condition,
personnel must be stationed at the  sites during the                g
episode or automated equipment must be  operated that can          I
provide automatic data transmission to  a central  location.         ™

Episode conditions threaten human welfare, and monitoring         •
sites should be located in areas where  this welfare  is            I
most threatened:

1.  In densely populated areas.                                   I

2.  Near large stationary sources of pollutants.

3.  Near hospitals.                                               V

4.  Near high-density traffic interchanges.                       •

5.  In homes for the aged.

A network of sites is useful in determining the range of          I
pollutant concentrations within an  area.  Although the most       •
desirable monitoring sites are not  necessarily the most
convenient, consideration should be given, for reasons            •
of access, security, and existing communications, to the          |
use of public building: schools, firehouses, police
stations, hospitals, and water or sewage plants.                   _

o Trend Monitoring                                                •

As typified by the National Air Surveillance Network (NASN),       •
trend monitoring is characterized by locating  a minimal           |
number of monitoring sites across as large an  area as
possible.  The program objective is to  determine, in a            •
broad sense, the extent and nature  of air pollution  as            •
well as determine the variation in  the  measured levels            ™
of atmospheric contaminants in respect  to geographic,
socioeconomic, climatologic and other factors.  The  data          •
acquired are useful in planning epidemiological investigations    I
and also provide the background against which  more intensive
community and state-wide studies of air pollution can be          M
conducted.                                                        •
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Urban sampling stations are usually located  in  the  most
densely populated areas of a region.   In most  regions
there are several urban sites.

Nonurban station loctions include various topographical
categories such as farmland, desert,  forest, mountain,
and coastal.   The nonurban stations are not  specifically
selected to be "clean air" control  sites for urban  areas,
but they do provide for a relative comparison  between
some urban and nearby nonurban  areas.

In interpreting trend data one  must consider the limitations
imposed by the network design.   Even  though  precautions  are
taken to ensure that each sampling site is as  representative
as possible of the designated area, it is impossible to
be totally certain that the measurements obtained at a
specfic site are not sometimes  unduly influenced by
local factors.  Such factors might include topography,
structures, and sources of pollution  in the  immediate
vicinity of the site, and other variables, the  effect of
which cannot always be accurately anticipated  but which
should be considered in network design.  It  must be kept
in mind that when comparisons are made among pollution
levels for various areas, they  are valid only  insofar as
the sites are comparable.

o Research Monitoring

An example of a research-oriented air quality monitoring
effort is the EPA's Community Health  Air Monitoring
Program (CHAMP), which is providing data to  develop
criteria for both short- and long-term air quality  standards.
Air monitoring networks related to health effects are
composed of integrating samplers for  determining
pollutant concentrations for 24 hours, or longer for
developing long-term (_> 24 hours) ambient air  quality
standards.  These studies require that monitoring points
be located so that the resulting data represent the
population group under study.  The monitoring  stations
are therefore established in the center of small, well-
defined residential areas within a community.   Data
correlations are made between observed health effects
and observed air quality exposure.

Requirements for aerometric monitoring in support of
health studies are:

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1.  Station must be located in  or near the  population  under         |
    study.

2.  Pollutant sampling averaging  times must be  sufficiently         I
    short to allow for use in acute health  effects  studies
    that form the scientific basis for short-term  standards.

3.  Sampling frequency should be  sufficient to  characterize         I
    air quality as a function of  time, usually  daily.

4.  System should be flexible and responsive to emergency           •
    conditions with data available on  short notice.

o Meterological Factors that Affect Representative  Sample           I
  Collection                                                       •

Meteorology must be considered  in determining not  only             •
the geographical location of a  monitoring site, but also           |
such factors as height, direction and  extension of sampling
probes.  Meteorological parameters having the greatest             _
influence on dispersion of pollutants  are the direction,           •
speed, and variation of wind.                                      •

Wind direction provides an indication  of the general movement       •
of pollutants in the atmosphere.   Review of available  data can     |
indicate mean wind direction in the vicinity of the major sources
of emissions.                                                      «

The effects of wind speed are two-fold.  First, wind speed          ™
determines the travel time from source to receptor.  Second,
wind speed affects dilution in  the downwind direction,             •
i.e., concentration of air pollutants  is inversely proportional     I
to wind speed.

o Topographical Features that Affect Representative Sample          I
  Collection

The transport and diffusion of  air pollutants is complicated       I
by topographic features.  Minor topographic features may exert    I
small influence; major features,  such  as deep river
valleys or mountain ranges, may affect large areas.                •
Before final site selection, topography of the area               •
should be reviewed to ensure that the  purpose of monitoring
at that site will not be adversely affected.
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Final placement of the monitor at a selected monitoring
site depends on physical obstructions and activities  in
the immediate area, accessibility, availability of utilities
and other support facilities, correlation with  the defined
purpose of the specific monitor, and monitor design.
Because obstructions such as trees and fences can significantly
alter air flow, monitors should be removed from such
obstructions.  It is important that air flow around the
monitor should be representative of the general  air flow
in the area to prevent sampling bias.

Network designers are to avoid sampling locations that
are unduly influenced by down-wash or by ground dust,
such as a rooftop air inlet near a stack or a ground-level
inlet near an unpaved road.  In the latter case, either
elevate the sampler intake above the level of maximum
ground turbulence effect or simply place it reasonably
far from the source of ground dust.

o Sampling Schedules Consistent with Monitoring Objectives

Current Federal regulations specify the frequency of
sampling for criteria pollutants to meet minimum SIP
surveillance requirements.  Continuous sampling is
specified except for 24-hour measurements of total
suspended particulate matter and 24-hour integrated
values for S02 and N02.  The high-volume and gas impinger
measurements are required at least once every six days,
equivalent to about 61 random samples per year.   Twenty-
four-hour samples should be taken from midnight (local
standard time) to midnight and thus represent calendar
days to permit direct utilization of the sampling data
with standard daily meteorological summaries.

o Sample Preservation and Holding Times

During and after collection, if immediate analysis is  not
possible, the sample must be preserved to maintain its
integrity.  Proper handling of the samples helps insure
valid data; consideration must also be given to care of
the field container material and cap material,  cleaning,
structure of containers, container preparation  for determination
of specific parameters, container identification, and
volumes of samples.

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          Sample collection,  containers  and  preservation of industrial
          effluents for priority  p
          specified in  Appendix 6.
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          Sample collection  containers, preservatives and holding            |
          times for samples  collected  in the 106, 208, 404(b),
          1412  and  the  Great Lakes  National Monitoring Programs              •
          shall be  those  specified  in  Appendix 5.                            I
effluents for priority pollutants protocol  shall  be those          I
          Sample collection  and  preservation  protocol for hazardous          •
          waste samples  shall  be those  specified in Appendix 7.              g

          Sample collection  and  preservation  protocol for ambient
          air samples  shall  be those  specified in Appendix 8.                I

          Sample collection,  preservation and holding time protocol
          for the 1412 monitoring (public water supply) program              •
          shall be those specified  in Appendix 14.                           |

8.3  Analytical Methodology                                                  _
     The analytical  laboratory provides  qualitative and quantitative         I
     date for use in decision making.   To be  valuable, the data must         ™
     accurately describe the characteristics  and concentrations of
     constituents in the samples submitted to the laboratory.  In many       •
     cases, because they lead to faulty interpretation, approximate or       |
     incorrect results are worse than no results at all.

     Many analytical methods for environmental pollutants have been          I
     in use for many years and are  used in most environmental lab-
     oratories.  Widespread  use  of  an analytical method in environmental
     testing usually indicates that the method is reliable, and              •
     therefore tends to  support  the validity  of the reported test            I
     results.  Conversely, the use  of little-known analytical
     techniques forces the data  user  to rely  on the judgment of              •
     the laboratory analyst,  who must then defend his choice of              I
     analytical technique as well  as  his conclusions.

     Uniformity of methodology within a single laboratory as well            I
     as among a group  of cooperating  laboratories is required to             •
     remove methodology  as a variable when there are many data
     users.  Uniformity  of methodology  is particularly important             •
     when several laboratories provide  data to a common data bank            |
     (such as STORET)  or cooperate  in joint field surveys.  A
     lack of uniformity  of methodology  may raise doubts as to the
     validity of the reported results.   If the same constituents             I
     are measured bv different analytical orocedures within n                •
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single laboratory, or by a different procedure in different
laboratories, it may be asked which procedure is  superior,
why the superior method is not used throughout, and  what
effects the various methods and procedures have on the  data
values and their interpretations.

Physical and chemical measurement  methods used in environmental
laboratories should be selected by the following  criteria:

a.   The selected methods should measure desired  constituents
     or environmental samples in the presence of  normal inter-
     ferences with sufficient precision and accuracy to meet
     the environmental data needs.

b.  The selected procedures should use equipment  and skills
    ordinarily available in the average environmental  laboratory.

c.  The selected methods should be sufficiently tested  to
    have established their validity.

d.  The selected methods should be sufficiently rapid to
    permit repetitive routine use  in the examination of large
    numbers of water samples.

The restriction to the use of EPA  methods in all  laboratories
providing data to EPA permits the  combination of  data from
different EPA programs and supports the validity  of  decisions
made by EPA.

The QAO requires that the methodology be carefully documented.
In some reports it is stated that  a standard method  from an
authoritative reference was used throughout an investigation,
when close examination has indicated, however, that  this was
not strictly true.  Standard methods may be modified or entirely
replaced because of recent advances in the state  of  the art
or personel preferences of the laboratory staff.   Documentation
of measurement procedures used in  arriving at laboratory data
should be clear, honest, and adequately referenced;  and the
procedures should be applied exactly as documented.

Reviewers can apply the associated precision and  accuracy of
each specific method when interpreting the laboratory results.
If the accuracy and precision of the analytical methodology
are unknown or uncertain, the data user may have  to  establish
the reliability of the result he or she is interpreting before
proceeding with the interpretation.

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As part of any monitoring program's quality control  program,  the        I
analytical methodology must be included for review and  approval
by the Quality Assurance Office.   The format and  minimum               •
requirements for method documentation are listed  below:                 •

1.   Parameter that the method measures.

2.   Principle - A brief description of the method.                     I

3.   Optimum Concentration Range  - The analytical  range from            •
     the lowest concentration to  the highest concentration             |
     in which a substance is measured.  The sample may  be
     concentrated or diluted so that the substance can  be              _
     detected within this range.                                        I

4.   Sensitivity - The slope of a curve of concentration
     versus instrument response (such as absorbance).                   •

5.   Detection Limit - The lowest quantity which  may be
     be distinguished from zero with an acceptable degree              _
     of confidence.                                                    I

6.   Reference - The source of the analytical  method.   In
     addition all variances of the original procedure are              •
     documented here.                                                  |

7.   Matrix - The general composition of the sample that the            •
     method is capable of handling, e.g., water (potable,              •
     ambient, wastewater), solids (leachates,  sediments,
     sludges), air (filter particulates, bubbler  solutions,
     casette trap).  Fluids (solvents, hydrocarbons, oils).             •

8.   Analysis Procedure
     a.  Description - The analytical procedure is described            •
         for normal conditions.  Sample pretreatment (if               I
         required) and preparation protocols are  also
         described here.  The language used to describe
         the method is to be detailed enough (cookbook                  •
         fashion) so that a technician with experience  in              •
         the respective type of analysis would clearly
         understand every step of the procedure.   Analytical            •
         techniques that employ a great deal of instrumentation        |
         such as atomic absorption and automated  analysers are
         briefly described since instrument manuals are                _
         available which detail the use of the instrument.             I
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b.  Instrument parameters -  A description of the  instrument
    and all  the instrument settings that  are necessary
    to setup the instrument  for normal  conditions.

c.  Routine performance tests - A test  of the instrument
    performance which is separate from  a  calibration  procedure,
    and is a gross indication of the instrument's response.
    This test is performed and documented each time a
    batch of samples is processed or else on a daily
    basis.  The frequency chosen for instrument
    response check is dependent on the  analysts'
    confidence of instrument stability.

d.  Calibration standards -  The calibration standards
    are described in terms of the range of concentrations
    used in the normal  procedure and in terms of
    composition (preparation of standard  solutions)
    employed for various matricies.

e.  In-house quality control standards  -  There are
    standards which are different from  calibration
    standards.  Quality Control standards are meant
    to be a control procedure by which  to judge
    whether the procedure is in-control or out-of-control
    after the various instrument checks have been
    satisfied.  Wherever used, at least one quality
    control  standard is determined with each batch of
    samples.  The information is then documented.

    1.  one wheel of samples - for auto analyzer
        techniques.

    2.  a number of samples  that is determined
        continuously without an interuption such  as
        a coffee or lunch break or a change of
        instrument settings  - for atomic  absorption
        techniques, manual techniques,  and gas
        chromatographic techniques.

f.  Data calculations - Describe the computations and
    manipulations that must  be used to  convert raw
    data to a final analytical  results.

g.  Instrument log book - An indication of where  the
    instrument log book is located.  The  instrument

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                          36
          1.   Name,  Model  Number, Serial Number
4.  Service record
          specified.   The use  of real  sample  spikes  (positive
                                                                        I
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          book  is  to  contain, as a minimum, the following                I
          sections:
                                                              I
          2.   Does  the  identification verify that the instrument
              is  EPA  approved, if required                               •

          3.   Instrument  history
                                                                       I
        ^  5.   Routine  performance test - This section includes
              a space  for the date, initials of analyst,                •
              comments,  and  other instruments parameters                |
              if applicable.

 9.    Interferences  -  When interferences are suspected or               •
      indicated by other tests, the specific procedures for             ™
      dealing with these interferences are described here.

10.    Precision and  Accuracy                                           |
      The statistical  precision and accuracy results for the
      parameter generated by the laboratory are to be                   •
      documented.                                                       I

11.    Quality Control
      a.  Internal Quality Control -  In-House Quality Control           I
          Standards, in  addition to being controls, are to be           •
          used as a  measure  of precision under ideal
          conditions.  Frequency of use is to be specified.             •
          Reagent Blanks are to be determined to collectively           |
          check for  possible contamination from the sample
          container, preservative, glassware, and laboratory
          reagents.  Frequency of use is to be specified.               •
          The use of replicate analysis of real samples to              •
          measure precision  is viewed as a product of the
          laboratories.   This information is meant for use              •
          in interpreting analytical  results and is of some             |
          use to the laboratory for evaluating the reported
          detection  limits and detecting possible interferences         •
          that might not be  documented in the original method.          I
          The use of replicates is dependent on the parameter           *
          (the number  of samples with positive values) and the
          analytical method.  Frequency of use is to be                 •
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                or negative)  is  also dependent  on  the  convenience
                with which they  fit  into the analytical  procedure.
                Spike are useful  for evaluating recovery in
                addition to precision.   Frequency  of use is  to
                be described.

            b.  External Quality Control  -  Participation in  various
                comparative analytical  programs and  frequencies
                outside of the laboratories are cited  here.

8.3.1  Maintenance of Up-To-Date File of Measurement Methods
       The Central Regional Laboratory (CRL) currently uses
       over 200 approved reference methods  to analyze  over 500
       different environmental pollutants.   It  is  known from recent
       on-site inspections that  the  nine principal State laboratories
       in the Region use many analytical  methods not used by the CRL
       and that they have made "minor" variations  in methods in
       common use by EPA.  The variety of new methods  in use by the
       other Federal and local laboratories is  not yet known, but  it
       is expected that the total number of agency approved  laboratory
       methods the QAO will be evaluating will  number  well over
       1,000.

       In addition to the laboratory methods, the  QAO  must monitor the
       performance of sampling procedures used  by  the  monitoring programs
       conducted by Region V  and a wide variety of field measurements.
       These include measurement of  the common  water parameters such
       as temperature, flow,  dissolved oxygen,  pH, etc., as  well as
       the measurement of air pollutants using  both  continuous monitors
       and grab sampling techniques.

       Each of the above methods must be technically evaluated and a
       decision made for each method as to  whether or  not the method is
       legally approvable for use in one or more of  the many programs
       administered by EPA.  For example, is the inductively coupled
       argon plasma procedure used by the CRL to analyze for metals
       significantly different from  the approved atomic absorption
       procedure to prohibit  it  use  in the  analyses  of public drinking
       water samples.  A conservation QAO opinion  would answer yes
       and therefore require  the CRL to either  use the manual method
       or obtain an alternate test procedure approval  pursuant to
       the Safe Drinking Water Act.   Either action would require at
       least 0.5 man years of effort which  clearly identifies the  importance
       of making the correct  decision for each  method-program combination.
       It should be again emphasized that the QAO  program requires that
       each approved measurement method contain a  complete description
       of all quality control  audit  procedures  and the frequency and
       control limits to be used to  insure  reliability of reported

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                 38
Recommended analytical  methodology for priority
pollutants is referenced in Appendix  6.   Sample
preparation and analysis for hazardous waste are
those specified in Appendix 7.
                                                              I
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data.  Therefore, when a method is  approved,  the  quality                j
control program associated with that  method will  also  be
approved.

In summary, this function is not a  "bookkeeping"  job and  is             •
probably the most difficult work performed by the QAO.   It
requires in-depth technical and program skills as well  as a             •
great deal of organizational ability  and diplomacy to  negotiate         |
satisfactory resolutions to the many  problems currently facing
the QAO in this area.   QAO's initial  approach toward completing         _
this task  is described below.                                           •

1.   Program Guidelines and Implementation Plans
     a.  The Reference Methods described in the various EPA             •
         regulations will serve as  the basis  for  all method             I
         evaluations.   Results obtained using the reference
         methods will  be taken as the officially  correct  results        •
         even though it is known the  result may not always              •
         accurately measure the contaminant concentration of           m
         interest.

         EPA offical analytical methodology for water  quality          I
         measurements are given in  Appendix.  9.  Radiation
         methods are shown in Apendix 10.  Ambient air                 •
         measurement methods are shown in  Appendix 11.   Source          •
         air measurements analytical  methodology  are shown in
         Appendix 12.   Public water supply measurements                _
         analytical methodology are shown  in  Appendix  13.              I
         Recommended analytical methndnloav for orion'tv                •
                                                                       I
Analytical  measurements for ecological  evaluations  of         _
proposed discharge of dredged  or fill material  into           •
navigable waters are listed in Miscellaneous  Paper             •
D-76-17, titled Interim Guidance for Implementation of
Section 404(b)(l)  of Public Law 92-500  (FWPCA Ammendments      •
of 1972), compiled by the U.S. Corps of Engineers.             |

A unique number will be given  to each method  as it  is         •
approved.  This will permit the QAO to  more easily             •
use computers to quickly retrieve information related
to the method.  The unique number will  contain the
following intelligence.                                       I

o Laboratory usi ng method

o Sample type (air, water, sediment, biological)               •
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    o Parameter class (biological,  organic,  inorganic)

    o Parameter (zinc, aldrin,  TSP)

    o Reference or alternate method

    o EPA programs method may be used to support

c.  Software programs will be written which  will  associate
    other information with each approved method using the
    method number as a cross index.   Some of the  related
    information will be as follows:

    o QAO file folder where the "official" method description
      is maintained.

    o A list of literature references supporting  the method.

    o The STORET, SARAD, etc.,  numbers related to the method.

    o The appropriate reference method if the method is  an
      alternate test procedure.

    o All quality control audit data.

    o A comment space for user remarks pertaining to method
      performance.

d.  A cross-indexing system will be established in which one
    can obtain a list of approved laboratory-method combinations
    for each EPA program and a  list  of programs for which
    each laboratory is approved to  use each  of its
    described analytical methods.

e.  All approved methods will be reviewed at least once
    each year (January - March) to  insure that they are
    properly classified relative to any regulatory or
    technical changes thay may  have occurred during the
    year.

f.  A numerical  description of  the  performance of each
    method will  be obtained from the group evaluating the
    interlaboratory quality control  audit data.  These

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        equivalent or better than the reference method.   Unfortunately,
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                                  40

                 numbers will  be evaluated,  interpreted  and  a  description       I
                 will  be prepared explaining the  performance of the
                 method for non-technical  personnel.   It  will  provide
                 references to related methods.                                 •

             g.   The out-puts  will  be:

                 o An up-to-date list  of all  approved  and some unapproved       |
                   (those being processed,  but  not  formally  approved)
                   methods for making  any measurement.   Each of these           _
                   methods will  have  a list  of  programs  which  may              I
                   be used to  support  the reference method,  the proper         •
                   number to use for  storage of results  (STORET,  SARAD),
                   the units of measure, the method performance data            •
                   (detection  limit,  working concentration range,              |
                   precision and accuracy)  and  laboratories  approved to
                   use the method.                                              «

                 o A copy of any approved method(s) and  any  approved quality
                   control program(s).

                 o An evaluation of methods  which were not approved  for  use    I
                   by the QAO  in the  proposed program  with justification
                   for non-approval.                                            •

             h.   Relationship  to other QAO functions
                 These official  measurement  methods will  form  the
                 foundation of the QAO program  for  monitoring  data             I
                 reliability.   They will be  the "contract agreement"            •
                 between the QAO and  all media  offices and will  provide
                 the written communication link  for use  in legal  and            •
                 technical challenges.  They will provide a  management         |
                 structure for evaluating and documenting differences
                 in method and laboratory performances resulting from           —
                 "minor" changes in analytical  methods and laboratory           •
                 operating procedures.                                         •

8.3.2.  Alternate Test Procedure Program                                       •
        The Code of Federal Regulations (40  CFR  136,                            |
        40 CFR 35, 40 CFR 141, etc.),  specifies  that  specific  analytical
        methods be used to monitor compliance with  several regulations         «
        administered by EPA.  In each  instance,  the regulations provide         •
        a mechanism by which an alternate analytical  procedure can be           ™
        used in place of the specified reference  procedure if  it is
        first documented that  the proposed alternate  procedure is              •
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I                   the different EPA programs specify different analytical mthods
                     to be used to analyze for a given contaminant and different
_                   mechanisms for obtaining approval to use an alternate test
•                   procedure.  This requires EPA to maintain records for all
•                   programs  (NPDES, SDWA, etc.)-method (Flame AA, ICAP, Flameless
                     AA, etc.)-laboratory combinations to insure that reported data
•                   can be used for regulatory purposes.

                     For Region V, the QAO is responsible for processing all alternate
I                     test procedure applications in the water program areas.  Depart-
                     ment E, EMSL-RTP, Research Triangle Park, North Carolina, has
                     sole national responsibility for implementing designated
                     reference and equivalent methodologies for the air programs
I                     as specified by 40 CFR 53.1.  The Region V alternate test
                     procedure protocols are described below by program.


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8.3.2.1  Elements of an Application for a  National  Pollutant  Discharge
         Elimination System (NPDES) or Section  106  Alternate  Test
         Procedure
         40 CFR 136, "Guidelines Establishing Test  Procedures
         for the Analysis of Pollutants",  specifies approved  test
         procedures for NPDES self-monitoring and data  submitted to
         condition an NPDES permit.

         Appendix H to 40 CFR 35,  specifies  approved test  procedures
         be used by a pollution control  agency  to show  compliance  or  non-
         compliance with an NPDES  permit.  Other monitoring programs
         (ex. - PCB toxic pollutant monitoring)  specify the use of 40
         CFR 136 test procedures.

         40 CFR 136 selects specific documented  test procedures from
         "Standard Methods", EPA's "Methods  for  Chemical Analysis  of
         Water and Wastes", and "ASTM, Part  31", on a pollutant-by-
         pollutant basis, for the  analysis of NPDES effluents.  Based
         on the knowledge available to EMSL-Cincinnati, EPA,  these
         test procedures were selected as  the best  available  test
         procedures for effluent analysis  -  physical, chemical or
         microbiological.

         40 CFR 136.4 and 136.5 specifies  that  alternate test procedures
         may be used if approval either is obtained from the  Regional
         Administrtator on a case-by-case  basis, or from the  U.S.  EPA
         Administrator on a nationwide basis.  Alternate test procedures
         are justified by, but are not limited to,  increased  analytical
         performance and increased cost  effectiveness to the  approved
         method(s), or are proposed because  they ara promising new

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       or 208 program.
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methodologies.  Alternate test procedure applications  are               I
processed by U.S.  EPA if an applicant  can justify their use
for NPDES monitoring.

The Regional Administrator approves  alternate  test procedures  on        •
a case-by-case basis for specific NPDES permits  within the specific
U.S. EPA REgion and specific laboratories (public agency and            •
commercial) receiving NPDES samples  from a finite portion  of            |
an EPA Region.  Appendix H to 40 CFR 35 specifically provides
authority to the Regional Administrator for approval of alternate       _
test procedures in State laboratories.                                  I

a.   NPDES Alternate Test Procedures for Nationwide Use
     Contact the Director, Environmental  Monitoring and Support         •
     Laboratory (EMSL)-Cincinnati, EPA, Cincinnati, Ohio 45268,         |
     phone (513)684-7301 or phone FTS  684-7301 for the protocol
     concerning alternate test procedures for  nationwide use.           •

b.   Elements of an NPDES Alternate  Test Procedure Application on  a     ™
     Case-by-Case Basis
     Until and unless printed application forms  are made available     I
     from the U.S. EPA, any person may apply to  the Regional            I
     Administrator in the Region where the discharge(s) occurs,
     through the Director of the State Agency  having authority         •
     to issue NPDES permits within such State.                         I

     An application should be made in  triplicate to the Regional
     Administrator and shall:                                          I

     o Provide the name, address, and  telephone  number of  the
       responsible person, firm or public agency making                •
       application.                                                    |

     o Identify the pollutant(s) for which approval is sought.         _

     o Specify the applicability of  the proposed test  procedure.        •
       Applicability of an alternate test procedure can be
       sought for (1) one or more specific NPDES permits (in this       •
       case, the applicable I.D. number(s) must  be provided),           |
       (2) all or certain types of NPDES discharges monitored,
       within a geographical area of the Region, by a  commercial        _
       laboratory or by a pollution  control agency laboratory           I
       (State or Federal); or (3) all  or certain types of               ™
       non-point source monitoring provided by a pollution
       control agency laboratory as  part of a  Section  106               •
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o Provide a justification for use of the  proposed method.
  This can be, but is not limited to, increased  analytical
  performance or cost effectiveness.

o Provide a detailed description of the proposed alternate
  test procedure.  This should be written in  sufficient
  detail that another laboratory could reproduce the
  applicant's equipment and instrumentation.   This  is  a
  necessary part of the application,  since final approval
  can only be given for a documented test procedure
  description.  Suggested formats for a detailed description
  can be found in "ASTM, Part 31", "Standard  Methods", or
  EPA's "Methods for Chemical Analysis of Water  and Wastes".

o Provide the concentration range of interest for the
  pollutant(s) identified in the above item.   In the case
  of specific NPDES permits, present and  expected effluent
  limitation concentrations shall be documented.  In the
  case of non point source waters, the criteria  or
  standards, which the monitoring program is  to  assess,
  shall be documented.

o Provide the detection limit, and its definition for  the
  proposed alternate test procedure.

o Provide copies of, or cite reference to any published
  studies, if available, on the applicability of the
  alternate test procedure to the NPDES effluent types in
  question.

o Provide data, using sample aliquots of  representative
  waste effluents (and untreated or raw wastes,  if
  appropriate), showing the proposed method yields
  results comparable in equivalency and precision to the
  reference method, or one of the reference methods,
  specified by 40 CFR 136.  The comparability data
  protocol listed in one of the following two items
  will be used.

o For an NPDES discharger, with one to four effluents
  of the same waste characteristic, provide comparability
  data by the following protocol.  Select at  least  eight
  different effluent aliquots, collected  over a  representative
  time period, to provide varying concentration  levels of the
  pollutant of interest.  Determine or measure the
  pollutant of interest by the proposed test  procedure

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                   44

and by a reference method.   Specify the reference  method          I
used.  Spike each of 8 aliquots,  described above,  with
the pollutant of interest.   Select spike concentrations
so that the present spike recovery can be calculated              I
from the amount of spike added.   The chemical  compound,           •
selected to use as a spike material  should assess  the
complete proposed test procedure  or be representative            •
of the chemical compounds or products of interest  in  the          |
industrial  or municipal  process of interest.   For  example,
organic nitrogen or phosphorus compounds should be               _
selected as a spiking material for a Kjeldahl  nitrogen            I
or total phosphorus test procedure in order to include            ™
assessment  of the digestion steps.  Orthophosphate or
ammonia compounds would only assess suitability of the            •
final measurement step.   After spiking of the  waste              |
aliquots, determine the pollutant concentrations by
both the proposed method and by the reference  method              m
of choice.   Calculate percent recovery on the  basis of            I
the amount  of spike added.   Specify the chemical
compound used as a spike material.

If it is expected that the average percent recovery              I
for the spike added will be between 95% and 105%,  that
the chemical compound selected for spiking is  appropriate,        •
and that significant concentrations of the pollutant  of           J
interest is present in the waste  effluent aliquots, it
will be unnecessary to analyze spiked samples  by the              —
reference method.  If inadequate  spike recovery by the            I
proposed method is obtained, spike recovery by the               •
reference method must be provided for comparative
purposes.                                                        •

If it is expected that there will be undetectable
amounts of the pollutant present, either by the proposed          _
method or by the reference method in unsplked  samples,            I
then equivalency data must be provided using both                 ™
spiked and unspiked samples by the two test procedures.

Provide precision data for comparability of the two              |
methods, either by analyzing the  above eight effluent
aliquots in duplicate by the two  methods or by selecting          «
a single waste aliquot of representative and detectable           I
pollutant concentration and analyzing at least eight
replicate values by each method.
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  Tabulate the above date to show equivalency  of  the
  proposed method with a reference method,  comparability
  or adequacy of spike recoveries and comparability of the
  two method's precision and accuracy.   Each effluent
  aliquot selected for comparability data should  be
  uniquely identified and described as  to appropriate
  NPDES Permit Number.  All  data  collected  during the
  comparability studies must be provided.  Provision of
  comparability data can not be made on a selective
  basis.

o For an NPDES discharger laboratory, State laboratory,
  commercial  laboratory, or  U.S.  EPA laboratory seeking
  approval for use of an alternate test procedure for  a
  variety of NPDES permits,  for all  NPDES permits within
  a finite geographical area of EPA, Region V, or for  all
  NPDES permits for specific industrial or municipal
  categories in a finite geographical area  of  EPA,
  Region V, comparability data will  be  provided by the
  following protocol.

  Provide equivalency data,  by both the proposed  and
  reference methods, using 15 to  25 aliquots.  The aliquots
  selected must be representative of the applicability
  specified above.

  Provide spike recovery data, as appropriate, for the
  above 15 to 25 aliquots.  Specify the chemical  compound
  used as a spike material as discussed above.

  Provide precision data for comparison purposes,
  either by analyzing the above 15 to 25 aliquots in
  duplicate by the two methods, or by providing eight  or
  more replicate analyses of at least three or more of the
  15 to 25 aliquots by the two methods.

  Tabulate all of the above  data  for comparative  purposes.

  Until or unless printed application forms or a
  national U.S. EPA policy for a  comparability data
  protocol is implemented, a case-by-case NPDES alternate
  test procedure application in Region  V will  contain  the
  above items.  It is impossible  to specify a  comparability
  data protocol that is applicable in all situations.
  Applicants seeking a case-by-case approval are  encouraged

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o Provide present and future NPDES  effluent  limitations  in
  concentration units.
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                     46

  to contact the appropriate  State  pollution control agency        |
  or the Quality Assurance  Office,  Region V, EPA,  prior to
  initiation of comparability studies which do not  fit             M
  the protocols provided  in above items.  Examples  of this         I
  are proposed test procedures for  suspended solids which          *
  do not allow spiking, pollutants  whose test procedure
  defines the pollutant (BOD, oil and grease, suspended            •
  solids, fecal coliform, etc.)» and alternative sample            I
  preservation techniques or  holding times.  A protocol
  for obtaining approval  of an alternative preservation            •
  technique or holding time,  for limited applicability,            I
  is described below.

  Requests are often made to  monitor a  certain                     I
  parameter or pollutant  in lieu of a pollutant specified          •
  by a NPDES permit (ex.  -  to monitor chemical oxygen
  demand to show BOD permit compliance, after a correlation        •
  factor has been established).  It is  the policy  of the           |
  Quality Assurance Office, Region  V, not to process these
  requests as alternate test  procedure  application.
  They should be processed  as a request to modify  an NPDES         I
  permit and should be directed to  the  Enforcement  Division,       •
  Region V.

Elements of an NPDES Alternative Sample Preservation or Holding    |
Time Application on a Case-by-Case  Basis
NPDES alternate test procedure applications are applicable         _
to replacement of a preservation technique or to extending         I
a holding time specified  by a reference method cited by            "
40 CFR 136.  Applications for such  requests are made to
the Regional Administrator  in the Region where the  discharge(s)    •
occurs, through the Director  of the State agency having            |
authority to issue NPDES  permits within such State.

An application should be  made, in triplicate, to the Regional      I
Administrator and shall:

o Provide the name, address and telephone number of the person,    •
   firm or public agency  making the request.                       •

o Identify the pollutant(s) for which approval is  sought.          •

o Specify the applicability of the  proposed test procedure -  i.e.,
  specific NPDES Permit Numbers.
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o Provide a justification for use of the proposed preservation
  technique - ex. - cost effectiveness.

o Provide a detailed description of the  proposed alternative
  preservation technique or holding time.   This is quite
  necessary since final approval can only be given for a
  documented test procedure.   Suggested  formats for a
  detailed description can be found in,  "ASTM,  Part 31",
  EPA's "Methods for Chemical Analysis of Water and
  Wastes", and "Standard Methods".

o If available, cite references or provide copies of published
  studies showing the applicability of the proposed technique.

o Provide data, using sample aliquots or representative waste
  effluents (and untreated or raw waste, if appropriate),
  showing the proposed preservation technique or holding
  time yields results comparable in equivalency (not
  biased against the approved technique) and in precision
  to the approved preservation procedure.

o For a single NPDES permitted effluent, provide comparability
  data by the following protocol.

Select at least fifteen different effluent aliquots,
collected over a representative time period, to provide varying
concentration levels of the pollutant of interest.

Each aliquot of waste should be split into four separate
sample bottles at time of collection.

Two aliquots are to be analyzed by an approved  test
procedure using the approved preservation technique.   The
remaining two aliquots are to be analyzed, by the same test
procedure, using the proposed preservation technique or
holding time.  The test procedure is to  be specified.
If the proposed preservation technique uses an  extended
holding time, then the maximum holding time, specified
in the proposed preservation techniques  detailed test
procedure description, should be used.

Pollutant values should be tabulated for each of the four
waste aliquots along with the corresponding dates of sample
collection, dates of analysis using the  proposed technique,
and dates of analysis using the approved preservation  technique.

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                                  48
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              All  analysis  values  determined  should be reported.  Data           I
              can  only be discarded  on the basis of quality control audit
              or control solution  values  showing a specific set of analyses
              to be out-of-control.                                              I

              All  analyses,  using  the two preservation techniques, should
              be performed  in  a  single laboratory using a single analytical
              methodology.
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    d.   Section 106  of Public  Law 92-500 Alternate Test Procedure Program
         If approval  of a  NPDES alternate test  procedure is given to             I
         to a State laboratory, then  approval will also be given for             •
         remaining non-point  source measurements  in the State's Section
         106 monitoring program, if so  requested.  The NPDES alternate           •
         test procedure's  working concentration range should be appropriate      |
         for the needs of  the Section 106 program.

         If a State requests  approval of an  alternate test procedure for         •
         non-NPDES monitoring,  it may do so  without providing complete           *
         comparability data  so  long as  a documented test procedure
         description  is provided, there are  sufficient published studies         •
         provided to  demonstrate its  utility, and/or there are sufficient        |
         intralaboratory quality control data in  existence to document
         its utility.  The Regional Administrator shall determine the            m
         need for additional  comparability data upon the recommendations         •
         of the Quality Assurance Office, Region  V.

8.3.2.2  Elements of  an Application for a Safe  Drinking Water Act                8
         (SDWA) Alternate  Test  ProcedureI
         The National Interim Primary Drinking  Water Regulations (NIPDWR),
         40 CFR 141,  implementing the SDWA,  specifies test procedures            •
         to use for NIPDWR contaminants.  40 CFR  141.27 states that              |
         with the approval,  both of a primacy State and of the EPA
         Administrator, a  laboratory  may use alternate test procedures.
         This authority has  been delegated to the Regional Administrator.        •

         A memorandum of March  10, 1977, from the Ofice of Water Supply
         (OWS), EPA,  specifies  the mechanisms for obtaining approval of          •
         SDWA alternate test  procedures.  Final approval is either               I
         given by the Regional  Administrator on a case-by-case basis
         to specific  water utilities, and State,  Regional EPA, and               _
         commercial laboratories or by  the OWS  on a nationwide basis.            •
         The alternate test  procedures  for nationwide use should be              •
         published in the  Federal Register.

         The mechanism specified by the March 10th memo is extremly              |
         cumbersome,  but it  does designate who  has authority for final
         decision making.                                                        _
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The Regional  Administrator is responsible for final  determination
of alternate test procedures for approved water utility,  State,
commercial, and Regional  EPA laboratories.   EMSL-Cincinnati  and
OWS, both of EPA, are responsible for the determination of
alternate test procedures for nationwide use.   Alternate  test
procedures approved, as of September 1978,  for nationwide
use, are contained in two OWS memorandums of September 1,
1977, and March 9, 1978 (Appendix 15)

If approval of an alternate test procedure  has been  given by the
Regional Administrator on a case-by-case basis, to a private or
public laboratory for NPDES monitoring,  approval  for monitoring
of the same pollutant as a SDWA contaminant will  also be
given by the Regional Administrator, upon request, so long  as
the original  NPDES application clearly documents  the alternate
test procedure's working concentration range is applicable  to
measurement at the Maximum Contaminant Level (M3L) specified
by the NIPDWR.

a.  SDWA Alternate Test Procedure for Nationwide  Use
    Contact the Director, Environmental  Monitoring and Support
    Laboratory (EMSL)-Cincinnati, EPA, Cincinnati, Ohio
    45268, phone (513)684-7301 or phone  FTS 684-7301, concerning
    the protocol for SDWA alternate test procedures  for nationwide
    use.

b.  Elements ofaSDWA Alternate Test Procedure Application
    on a Case-by-Case Basis
    Approval  of an alternate test procedure can be requested
    by a water utility, public, or private  laboratory that  has
    made application for, or has, Interim Laboratory Certification
    under an existing State or Federal SDWA laboratory approval
    program in Region V,  EPA.

    Application for use of an alternate  test procedure, on  a
    case-by-case basis, is made in quadruplicate  to  the Regional
    Administrator, through the State water  supply program for
    those State which have accepted primacy for the  SDWA.   In
    non-primacy States, application is made directly to the
    Regional  Administrator.

    Until or unless printed application  forms  are made available
    from the U.S. EPA on a national basis,  a case-by-case
    application in Region V, EPA shall:

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o Provide the name,  address  and  telephone  number  of  the           •
  responsible person making  application.

o Identify the SDWA  contaminant(s)  for which  approval  is          |
  sought.

o Specify the applicability  of the  proposed test  procedure        I
  either for a specific utility, or utilities,  or for  a
  specific public agency or  commerical  laboratory doing
  work for utilities.                                            •

o Provide a justification for use of the proposed method-
  ology instead of a reference methodology.                       •

 °Provide a detailed description of the proposed  test  pro-
  cedure.  See "ASTM, Part 31",  EPA's "Methods  for Chemical
  Analysis of Water and Wastes", or "Standard Methods",           I
  for suggested formats.                                         •

 "Provide data showing the proposed method yields results         •
  comparable in equivalency  and  precision  to  a  reference          |
  method or an alternate test procedure approved  for
  nationwide use, in the concentration range  of the               _
  NIPDWR M3L.  Comparability data for 1 to 4  utilities,           •
  of equivalent water characteristics, shall  be provided          ™
  using the NPDES protocol for eight effluent aliquots.
  If approval is sought by a commercial or public agency          •
  laboratory for use for all utilities in  a State, then           |
  the NPDES comparability data protocol using 15  to  25
  different water utility aliquots  should  be  utilized.           _
  Sample aliquots will have  to be spiked,  at  or near the          I
  contaminant's PCL, and should  be  measured by  both  the           *
  proposed and approved methods. Organo arsenic  and
  organo mercury compounds shall be used as spiking               •
  compounds for these two contaminants, because their             |
  reference methods  contain  specific digestion  procedures.
  For a wide applicability,  sample  aliquots,  selected             •
  for comparability measurements must be a wide cross-section    I
  of the potable water in a  State.                                m

o Provide the proposed method's  detection  limit and  precision    I
  at the contaminant's MCL.   The terms detection limit and
  precision shall be defined by the applicant.
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                                   51

8.3.2.3  Processing of Case-by-Case Alternate Test Procedure  in  Region V
         a.  A NPDES discharger,  water utility,  or laboratory should
             make application in  triplicate,  for use  of a  case-by-case
             alternate test procedure, to the Regional  Administrator,
             through the responsible State authorities  having authority
             to enforce the National Pollutant Discharge Elimination
             System (NPDES) program or the Safe  Drinking Water Act
             (SDWA).  An extra application copy  is provided State
             authorities.   If the State does  not have appropriate
             enforcement authority, then application  is made, in triplicate,
             directly to the Regional  Administrator.

         b.  Application for nationwide use of an NPDES or SDWA
             alternate test procedure is made directly  to  the Director,
             EMSL-Cincinnati, EPA, Cincinnati, Ohio 45268, in accordance
             with EMSL-Cincinnati *s protocols.

         c.  For a case-by-case application,  the State  authorities
             will forward three copies of the application  to  the Regional
             Administrator with the States' recommendations.   The
             regulations specify  the State agency Director shall
             forward this application to the  Regional Administrator.
             Guidance from the Office of Water Supply (OWS),  EPA,
             specifies this shall  be done by  an  appropriate State Official.

         d.  Upon receipt of the  application  with State recommendations,
             (when the application is applicable to a State with delegated
             enforcement responsibility), the Regional  Administrator
             will forward the application, in triplicate,  to  the Quality
             Assurance Office (QAO), Region V, for processing.   Upon
             receipt of the application, the  QAO, Region V, will acknowledge
             receipt of the application to the applicant.  This  starts
             the time cycle for action on the request so that a  final
             determination on the request can be made within  90  days
             by the Regional Administrator.

         e.  If a State with enforcement responsibility for the  SDWA
             or NPDES program recommends disapproval  of the proposed
             test procedure, the  Regional  Administrator shall  deny the
             application.   Copies of this disapproval will be sent to
             the appropriate State agency and to its  State Laboratory
             Director, to the Director, EMSL-Cincinnati, and  in  the
             case of SDWA applications to the Office  of Water Supply
             (OWS), EPA.

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f.  The QAO will  review the application  for  the  following:
    reflects final authority by the Region and is  consistent
    with broad national  EPA policies.
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    o A clear understanding  of the  applicability  of the  proposed        _
      test procedure.                                                   I

    o A test procedure documented in  sufficient detail that  another
      laboratory could reproduce the  results  of the applicant's         •
      laboratory.                                                       I

    o Comparability data in  sufficient  quantity and consistency with    _
      the proposed applicability of the alternate test procedure.       I

    o Consistency with the data quality needs of  the  SDWA, NPDES
      program, and other monitoring programs  as appropriate.            •

    If any of the four elements are missing,  the  QAO  will  request
    the necessary information from  the  applicant  within  one             •
    month of receipt of the  application.   When the applicant           J
    provides this information to the  QAO,  a  new 90 day cycle
    will be initiated.

g.  If the application is complete, the QAO  will  forward a             •
    copy to the Director, EMSL-Cincinnati  for his technical
    review and recommendations, within  two weeks  of receipt             •
    of the alternate test procedure application.                        |

h.  At the discretion of the QAO, a copy of  the application
    will be forwarded to the Water  Supply  Branch, Region V,             I
    or to the Enforcement Division, Region V, for their  recom-          •
    mendations, if program policies are affected  by either
    approval or disapproval  of the  application.                         •

i.  Within the 90 day time period,  the  QAO will receive  all
    appropriate recommendations and prepare  a letter  for the           _
    Regional Administrator's signature  to  notify  the  applicant          I
    of approval of rejection, and in  some  instances specify             *
    the additional information which  is required  to deteremine
    whether to approve the proposed test procedure.   Copies             •
    of this final determination by  the  Regional Administrtor           I
    shall be forwarded to appropriate Regional and State
    program personnel, to the State Laboratory Director(s)             •
    of the concerned State(s), to the Director, EMSL-Cincinnati,        I
    and in the case of SDWA  approvals,  to  the Director,  OWS.
    The QAO will prepare the final  determination  letter  for
    the Regional Administrator so that  this  determination              •
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8.3.2.4  Procedures for Equivalent Test Prodcedure Under the Clean Air Act
         Methods required by the Clean Air Act are designated as  Reference
         of Equivalent Methods according to 40 CFR 53.1.   The use of
         methods which are not so designated must be approved by  Depart-
         ment E, EMSL-RTP.  Procedures for obtaining approval  of  a
         non-designated method are described in 40 CFR 53.4 and 40 CFR
         53.14, respectively.  These procedures require that any  user
         modifications which are not reference or equivalence must be
         approved by Department E, EMSL-RTP.

     8.4 Instrumentation
         All monitoring equipment and instrumentation pruchased within
         Region V with EPA grant, contract, inter-agency agreement, or
         operation funds are to be evaluated and recommended for  approval
         or rejection by the QAO.  For external monitoring projects,
         including 201 grants used to purchase monitoring equipment,
         the Project Officer will submit the equipment or instrumentation
         request and any justifications to the QAO through appropriate
         channels for review.  Internal office Directors and Branch
         Chiefs (Region V) will submit their proposals and justifications
         through the appropriate Division/ Office Director to the QAO
         through the Surveillance and Analysis Director for review.
         As part of the evaluation and approval process the following
         minimum points are considered.

         o Is there a need, present or future for the item, i.e., does
           present or projected regulations specify tests that  this equip-
           ment will be used for.

         o Does the purchaser have equipment in-house that can  be
           modified or adapted to perform the necessary function  at a
           lesser cost.

         o Wi11 the purchaser have the necessary auxiliary in-put,
           eg., if G.C. - Mass spectroscopy unit is requested,  will
           library facilities be available.

         o Are there technically competent personnel available  to
           operate the equipment.  If not, what plans are available for
           hiring or training such personnel.

         The QAO will forward an official  recommendation of approval
         for funding/purchase or a recommendation for not funding/purchase
         to the appropriate project officer, Division/Office Directory
         through appropriate channels.   In the case of not recommending
         funding/puchase a justification is also provided.

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8.5  Calibration and Standards                                               |
     Calibration procedures  require the  application of primary or
     secondary standards.  The  standards used, whether they are              _
     apparatus or reagent  standards are  to  be certified as being             I
     traceable to standards  of  the National Bureau of Standards,             •
     or other recognized fundamental  standard.  This type of trace-
     ability is possible when standards  are generated in the laboratory.     •
     Regardless of the type  of  calibration  equipment or material,            |
     an effective QA program requires accuracy levels of these
     materials that are consistent with  the method of analysis.              _
     The calibration policies and procedures outlined in 8.5 apply           I
     to all  measuring and  test  equipment/instrument associated               *
     with a  monitoring activity, including:

     o Sampling equipment  at sampling stations                               |

     o Analytical equipment/instruments  in  the laboratory                    M

     o Flow measuring devices (eg., current meters, rotameters) ,
       volume (eg., dry gas  meters),  pressure, vacuum and temperature
       measurement equipment at the sampling station and in the laboratory.  I

     As part of a monitoring activity's  (Federal, State, local
     agency, contractor or grantee) QA program a written step-by-step        •
     procedure for a frequency  for calibration of measuring and test         •
     equipment/instruments and  use of calibration standards is to be
     provided, in order to eliminate  possible measurement inaccuracies
     due to  difference in  techniques, environmental conditions, choice       I
     of higher level standards  and compliance with Agency regulations        •
     (eg., 40 CFR Part 58, Appendix A and B).  As a minimum, these
     procedures are to include  the following:                                •

     1.  The specific equipment or group of equipment (instruments)
         to which the procedure is applicatable.  Equipment of               _
         the same type, having  compatable calibration points,                I
         environmental conditions, and accuracy requirements, may be         •
         serviced by the same calibration procedure.

     2.  A brief description of the scope,  principle, and/or                 |
         theory of the calibration method.

     3.  Fundamental calibration specification, such as calibration          I
         points, environmental  requirements, and accuracy requirements.      ™
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                               55

     4.  A list of calibration standards  and  accessory equipment
         required to peform an effective  calibration.   Manufacturer's
         name, model number, and accuracy should be included  as
         applicable.

     5.  A complete procedure for calibration arranged in  a
         step-by-step manner, clearly and concisely written.

     6.  Calibration procedures are to provide specific
         instructions for obtaining and recording the  test data,
         and include data sheets that are to  be used.

     7.  A detailed documented sample of  computations  for  any
         calibration procedure that requires  statistical analysis  of
         results.

     8.  All field and laboratory calibration are to be traceable
         through an unbroken chain (supported by reports or data
         sheets) to some ultimate or national  reference standard.

     9.  An up-to date- report for each calibration standrd used in
         the calibration system is to be  made available for review
         during the QAO's audit or on-site system evaluation  of
         any monitoring activity in Region V,  funded by EPA.

     All equipment past due for calibration should be  removed
     from service either physically or, if this is impractical, should  be
     impounded by tagging or other means.

     The monitoring activity's quality control  official  or other
     individual delegated quality control responsibility (e.g., Lab-
     oratory Section Chief) has day-to-day responsibility  to  ensure
     that the monitoring activity maintains the required accuracy
     in the calibration program.

     The QAO will evaluate the monitoring activity's on going
     calibration and standards activity as part of the audit  and on-site
     evaluation process to ensure valid data  is being  produced.  Problems
     will be identified and recommendations for corrective action  provided.
     The QAO cannot validate data that is suspect.   Follow-up to validate
     and approve correction actions will  be QAO's responsibility.

8.6  Preventive Maintenance and Inspections
     As defined here, preventive maintenance  is an orderly program
     of positive actions (equipment cleaning,  lubricating, reconditioning,

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adjustment and/or testing)  for preventing failure Of monitoring          I
systems or parts thereof during use.   The most important effect
a good preventive maintenance program has is to increase measure-
ment system reliability and thus increase data completeness.             I
Conversely, a poor preventive maintenance program will  result            •
in increased measurement system downtime (i.e., decrease in
data completeness) and in increased unscheduled maintenance             •
costs; and may cause distrust in the validity of the data.   In          |
ambient air monitoring, data completeness criteria are  used to
validate data.                                                          _

A responsible individual (i.e., field section Chief, laboratory          '
Section Chief, QC Officer)  is required to prepare and implement
a preventive maintenance schedule for all equipment and measuring        •
systems, as part of the monitoring activity's total QC  program.          |
The planning required to prepare the preventive maintenance
schedule will have the effect of:                                       _

1.   Highlighting that equipment or those parts therof  that are          ™
     most likely to fail without proper preventive maintenance.

2.   Defining a spare parts inventory that should be maintained          |
     to replace worn-out parts with a minimum of downtime.

A specific preventive maintenance schedule is to relate to  the          I
purpose of testing, environmental influences, physical  location
of equipment, and the level of analyst skills.  Checklists  are
to be used as documentation for listing specific maintenance            I
tasks and frequency (time interval between maintenance).  In            •
some instances, if calibration tasks are difficult to separate
from preventive maintenance tasks, a combined preventive
maintenance - calibration schedule is advisable.
I
A record of all preventive maintenance and daily service checks        _
are to be maintained.  An acceptable practice to follow for            I
recording completion of task is to maintain a preventive maintenance   •
calibration multiple copy log book.  After tasks have been completed
and entered in the log book, a replicate copy of each task is          •
removed by the individual performing the maintenance - calibration     |
task and forwarded to the appropriate supervisor and QC Officer
for review and conformance with monitoring activity's preventive       .
maintenance protocol.  The log book is stored by the instrument        I
for future reference.  The QAO will review these log books             ™
during the audit or on-site systems evaluation activity for
deficiencies.                                                          •
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  8.7  Quality Control  Procedures
       Assuming that all  basic variables pertaining  to laboratory
       services (i.e.,  instrumentation,  glassware,  reagents,  solvents,
       gases, etc.) are under control, that  approved methods  are being
       used, and the complete system  is  initially under quality control,
       valid precision  and accuracy data must  initially be  developed
       for each method  and analyst.  Then,  to  insure that valid data
       continue to be produced, systematic  daily checks must  show  that
       the test results remain reproducible, and that the methodology
       is actually measuring the quantity in each sample.   In addition,
       quality control  must begin with sample  collection and  must  not
       end until the resulting data have been  reported. Quality control
       of analytical performance within  the  laboratory is thus but one
       vital link in generation and dissemination of valid  data for
       agency use.  Understanding and conscientious  use of  quality
       control among all  field sampling  personnel,  analytical  personnel,
       and management personnel is imperative.   Region V's  procedures
       are outlined in  the following  Sections  (8.7.1 and 8.7.2).
       Management of QC procedures (how  and  by whom) is described  in
       Section 10.2.

8.7.1  Intra-Laboratory Quality Control  Procedures
       The purpose of intralaboratory QC programs is to identify the
       sources of measurement error and  to  estimate  their bias (accuracy)
       and variability  (repeatability and replicability).   For manual
       measurement methods, bias and  variability are determined separately
       for sample collection and analysis and  are combined  for determination
       of total method  bias and variability.  For continuous  methods,
       total method bias and variability are determined directly.
       Some of the potential error sources  are the  operator or analyst,
       equipment, the calibration, and the  operating conditions.   The
       results may be analyzed by making comparisons against  each
       other and/or against reference standards.   To maintain a known
       level of competence in daily activities, quality control must
       be implemented in the field and at the  bench, using  a  system of
       checks to determine the accuracy  and  precision of results and
       the performance  of measurement systems  and operators.   Intra-
       laboratory quality control is  a continuing activity  to insure
       the output of data of known quality.  The specific objectives
       are to devise a  program that:

       o measures and control  the precision  of procedures and instruments.

       o measures and control  the accuracy of  analytical results.

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o documents, on a continuous basis,  the performance  of systems          •
  analysts and operators.                                               I

o establishes training needs.                                           M

o identifies weak measurement  methodology and provides feedback
  to the Quality Assurance Office,  where an evaluation can be
  made of the findings and the appropriate EMSL group notified          I
  so method revisions and/or modifications can be made.                 •

In Region V quality control charts  are to be the foundation            •
of the laboratory's inter!aboratory quality control  programs.          |
One form of quality control showing trends is the summation of
the differences squared for replicate samples.   Additional              _
control charts are recommended where standard deviations are           I
(d = Vd2/k) for use on a daily basis to establish rapidly if           •
an analysis is out of control  on a  given day.  Once  precision
and accuracy data are available on  the method and the operator/         •
analyst, systematic daily checks are necessary to ensure that          |
valid data are being generated.  From these daily precision and
accuracy data, quality control charts can be constructed and           _
maintained to determine when the method used is producing valid         I
data, when the data are questionable, or when a trend is detected      "
which must be investigated and corrected.

Several techniques are available for constructing quality control      |
charts and plotting subsequent data.  The two techniques currently
used by EPA are the Shewhart technique and/or Cumulative-Summation     f
technique.  These techniques are depicted in (EPA Publications)         I
EPA-600/4-79-019, Handbook for Analytical Quality Control in Water     •
and Wastewater Laboratories, March  1979, and Quality Assurance
Handbook for Air Pollution Measurement Systems, Volume I               I
(EPA-600/9-005), Volume II (EPA-600/4-77-0272a) and  Volume III          •
(EPA-660/4-77-027b).  For both techniques, precision control
charts are constructed from duplicate sample analyses, and             •
accuracy control charts are constructed from spiked  sample             I
analysis, utilizing standard reference materials (SRM).   SRM's
are substances which qualify as absolute quantities  against
which other like substances can be  calibrated or measured.  The         I
SRM, typically produced by organizations like the National             •
Bureau of Standards (NBS), is used  to prepare standard reference
standards (SRS) for routine laboratory and field use.                  •

SRS (also referred to as spiked samples) are preparations of known
amounts of standard reference materials added to an  actual environ-
mental samples which has been previously analysed.  The amount          I
of the substance found in the sample is a "true" indication of          •
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the accuracy of the method for a given measurement.   The  use  of
the standard reference samples measures the extent  of interferences
which cannot be obviated.

Following normal procedures, the control  chart  must  indicate
the conditions under which it was developed;  i.e.,  laboratory name,
parameter, method of analysis, date of preparation,  and any other
information unique to the  initializing data such  as  range of
concentration and identification of analyst(s)/operator.   A
control chart is not generally applicable under other conditions.

To verify the accuracy and precision of control charts, the
initializing data should be checked to be sure  that  none  of the
values exceeds these new control limits.   In  addition, if its
distribution is proper, about 68 percent  of the initializing
data should fall within the interval  average  percent recovery
plus or minus 2 times the  standard deviation  for  percent  recovery.
There is a question of validity of the control  chart if less
than 50% of the initializing data falls within  this  interval.

In application of the accuracy control  chart, either of the
following two conditions indicates an out-of-control  situation.

a.  Any point beyond the control limits.

b.  Seven successive points on the same side  of the  interval
    average percent recovery of the central  line  of  the
    completed control chart.

When an out-of-control situation occurs,  analyses shall be stopped
until the problem has been identified and resolved,  after which  the
frequency should be increased for the next few  percent recovery  QC
checks.  The problem and its solution must be documented, and all
analyses since the last in-control  point  must be  repeated or  discarded.

For some parameters it may be necessary to construct low  level and
moderate to high level accuracy QC  charts for each  standardization
concentration level sample.

In application of the precision control chart,  the chart  should
be updated periodically as additional,  or more  current, data
become available, or whenever the basic analytical system undergoes
a major change.  If any difference between duplicate analyses
exceeds the critical-range value for the  appropriate concentration
level, then analyses should be stopped until the  problem  is
identified and resolved, and the frequency is to  be  increased

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for the next few precision checks.   After resolution,  the problem      I
and its solution must be documented, and all  analyses  since the
last in-control  check must be repeated or discarded.

Once the quality control charts have been developed and put in         B
place, the normal  day to day working routine  requires  the following:

o A new standard curve should be established  with  each new             |
  batch of reagents, using at least seven concentration levels.
  The number of level in continuous monitors  is  3  levels within        _
  range.                                                               I

o With each batch of analyses (10 to 20% of the  time), the
  following tests are to be run:                                       •

  1. One blank on water and reagents.

  2. One midpoint standard.                                            •

  3. One standard reference standard (spike)  to  determine
     recovery.                                                         •

  4. One set of duplicate analysis.

The results from 2 through 4 are to be compared  with  previous          I
in-control data by using the-protocol  specified  above  (for a
detailed protocol description refer to Section 6.3 of  Chapter 6
of EPA Publication 600/4-79-019).                                      •

The following protocol is to be implemented to indisputably
establish the validity of data for  each parameter  from water           •
and wastewater projects:                                               |

In the following protocol the symbols used represent the
results of analysis according to the scheme:                            I

     AI = first replicate of sample A

     A£ = second replicate of sample A                                 |

      B = sample taken simultaneously with sample  A                    _

    Bsp = field spike into sample B                                    "

        = laboratory spike into sample B                               •
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                           61

    DF = field spike into distilled water

    D[_ = labortory spike into  distilled water

     T = true value for all spikes

The laboratory spikes B$L and  DL are the only analyses that may
not be necessary.  All other analyses must be done simultaneously.

Field personnel should perform the following steps for quality
assurance.

a.  Take independent simultaneous samples A and B at the same
    sampling point.  Depending on the parameter, this might
    involve s-ide-by-side grab  samples or composite samplers
    mounted in parallel.

b.  Split sample A into the equal-volume samples Aj and A2.

c.  Split sample B into equal  volumes and add a spike T to
    one of them; the latter sample becomes sample B$p.
    As with all spikes, the addition of T should approximately
    double the anticipated concentration level.

d.  Add the same spike T to a  distilled water sample furnished
    by the alboratory and designate this sample as Dp.

These QC samples must be treated in the same way as routine
samples; i.e., the volume, type of container, preservation,
labeling, and transportation must be same for all.

The laboratory pesonnel should perform the following steps for
quality assurance:

a.  Analyze the blank and midpoint standard recommended in
    the normal day-to-day working routine.  If results are
    unsatisfactory, resolve problems before continuing.

b.  Analyze sample Dp.  If the percent recovery of T is
    unsatisfactory (see accuracy protocol), create a
    similarly spiked, distilled-water sample D[_ and analyze
    to test for a systematic error in the laboratory or
    fundamental problems with  the spike.  If the percent
    recovery of T from D[_ is satisfactory, any systematic
    error occurred before the  samples reached the laboratory.

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                           62

c.  Analyze samples B  and  B$F-   If  B  is  below  the  detection             I
    limit, or if B is  greater  than  10T or less and O.IT,
    disregard the remainder of this step and proceed  to
    step d.  If the percent recovery  of  T from B$F is                  I
    unsatisfactory (see accuracy protocol), spike  an  aliquot            •
    of sample B the same way in the laboratory so  that a
    similar recovery can be anticipated.   Analyse  this sample           •
    BSI  to test for immediate  sample  interferences or a                 |
    bad background result  B.   If the  percent recovery from
    BSL is satisfactory, then  the interference must require             —
    a longer delay before  analyses, or other special  conditions         I
    not present in the laboratory,  in order to have a                  •
    noticeable effect  upon recovery of the spike.

d.  Analyze Aj and l\2'   ^ tne absolute  (unsigned) difference           |
    between these results  exceeds the critical  value  (see
    precision protocol), then  test  of precision is out of control.      g

e.  Calculate the absolute difference between  AI and  B.   If             *
    it is unsatisfactory (see  precision  protocol), the field
    sampling procedure did not provide representative samples.          •

If initial results at  each of  the laboratory steps were satisfac-
tory, then the validity of the related data has been  indisputably       M
established.  If results at any step  are unsatisfactory,  resolution     I
depends upon the problem identified.   Laboratory problems may
just require that the  analyses be repeated, but field problems
will usually require new samples.  Figure 8.7.1 is intended to          I
clarify the interdependence of the  preceeding  laboratory  steps          •
b through e.

In figure 8.7.1 it must be noted that there is no  way to  identify       |
additive sample interferences;  i.e.,  those that have  an equal effect
upon the background-pi us-spike results (B$p or B$[_) and the background
result B.  Recovery of a spike will not  show such  interferences.        I

Problems causing systematic errors  that  may occur  in  the  field
include the following:                                                  •

a.  Contaminated preservative, distilled water, or containers

b.  Contamination by sampling  personnel                                 I
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                                    63

         c.  Deterioration through excessive holding time or use of an
             ineffectual  preservation technique

         d.  Use of a bad field spiking procedure

8.7.1.2  Intra-Field Quality Control Procedures
         Quality control  programs for sampling equipment  and for field
         measurement procedures (of such parameters as temperature,
         dissolved oxygen, pH and conductance) are necessary to insure
         data of the highest quality.  A field quality control  program
         administered by a quality assurance coordinator  should contain
         the following documented elements:

         a.  The analytical  methodology; the special sample handling
             procedures;  and the precision,  accuracy, and detection
             limits of all analytical methods used.

         b.  The basis for selection of analytical and sampling
             methodology.  For example, all  analytical  methodology
             for NPDES permits shall be that specified by the Agency
             or shall consist of approved alternative test procedures.
             Where methodology does not exist, the quality assurance
             plan should state how the new method will  be documented,
             justified, and approved for use.

         c.  The amount of analyses for quality control expressed as
             a percentage of overall analyses, to assess  the validity
             of data.  The complete quality control program is to
             specify 5% as a minimum for time assigned to field QC.
             The plan should include a shifting of these  allocations
             or a decrease in the allocations depending upon the degree
             of confidence established for collected data.

         d.  Procedures for the recording, processing,  and reporting
             of data; procedures for review of data and invalidation
             of data based upon QC results.

         e.  Procedures for calibration and maintenance of field
             instruments  and automatic samplers.
         f.  A performance evaluation system, administered through the
             quality assurance coordinator,  allowing field sampling
             personnel to cover the following areas:

             (1)  Qualifications of field personnel for a particular
                  sampling situation.

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    (2)  Determination of the  best  representative  sampling               •
         site.

    (3)  Sampling technique  including  location  of  the  points             |
         of sampling  within  the  body of  water,  the choice of
         grab or composite sampling, the type of automatic               _
         sampler, special  handling  procedures,  sample                    I
         preservation, and sample identification.                        ™

    (4)  Flow measurement, where applicable.                             •

    (5)  Completeness of data, data recording,  processing,
         and reporting.                                                  •

    (6)  Calibration  and maintenance of  field instruments and
         equipment.

    (7)  The use of QC samples such as duplicate,  split, or              H
         spiked samples to assess the  validity  of  data.

g.  Training of all personnel  involved in any function                  |
    affecting the data quality.

Quality assurance in  sample  collection is to be implemented to           I
minimize such common  errors  as improper  sampling methodology,            •
poor sample preservation, and  lack  of  adequate  mixing  during
compositing and testing.                                               •

At selected stations, on a random time frame, duplicate  samples  are
collected from two sets of field equipment installed at  the site,       _
or duplicate grab samples are  collected.  This  provides  a check         •
of sampling equipment and technique for  precision.                      ™

A representative subsample from  the collected sample is  removed         •
and both are analyzed for the  pollutants of interest.  The samples      I
may be reanalyzed by  the same  laboratory or analyzed by  two
different laboratories for a check  of  the analytical procedures.        M

Known amounts of a particular  constituent are added in the field to
an actual sample or to blanks  of deionized water at concentrations
at which the accuracy of the test method is satisfactory.  The          •
amount added and frequency is  coordinated with  the laboratory.          I
This method provides  a proficiency  check for accuracy  of the
analytical procedures.                                                 •
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                                  65

        Acids  and  chemical preservatives can become contaminated after a
        period of  use in the field.  The sampler should add the same
        quantity of  preservative to some distilled water as normally
        would  be added to a wastewater sample.  This preservative blank
        is  sent to the laboratory for analysis of the same parameters
        that are measured in the sample and values for the blank are
        then subtracted from the sample values.  Liquid chemical
        preservatives should be changed every 2 weeks, or sooner,
        if  contamination increases above predetermined levels.

        A minimum  of seven sets each of comparative data for duplicates,
        spikes, split samples, and blanks should be collected to define
        acceptable estimates of precision and accuracy criteria for data
        validation of field parameters.

        Protocol is  to be developed and implemented for calibrating all
        field  analysis test equipment and calibration standards to include
        the following: (a) calibration and maintenance intervals, (b) listing
        of  required  calibration standards, (c) environmental conditions
        requiring  calibration,-and (d) a documented record system.
        Written calibration procedures should be documented and should
        include mention of the following:

        a.  To what  tests the procedure is applicable.

        b.  A  brief  description of the calibration procedure.

        c.  A  listing of the calibration standard, the reagents, and
           any accessory equipment required.

        d.  Provisions for indicating that the field equipment is
           labeled  and contains the calibration expiration date.

,7.1.3   Additional Intralaboratory Quality Control Procedures for
        Specific Groups of Parameters

        a.   Microbiology intralaboratory quality control.
            A quality assurance program for microbiological analyses must
            emphasize the control of laboratory operations and analytical
            procedures because the tests measure living organisms that
            continually change in response to their environment.
            Further, because true values cannot be provided for the
            microbial parameters, microbiologists do not yet have the
            advantages of analytical standards, QC charts, and spiked
            samples available to other disci plies for measurement of

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                      66

accuracy.  Because known values cannot be applied,  it is
important that careful  and continuous control  be exerted
over sampling, personnel, analytical  methodology, materials,
supplies, and equipment.

A documented inter!aboratory QC is to address  the following
areas as a minimum:

o An Operating Manual  shall  be prepared which  describes the
  sampling techniques,  analytical  methods, laboratory operations,
  maintenance and quality control  procedures.   Specific details
  are given on all procedures and quality control checks  made
  on materials, supplies, equipment,  instrumentation and
  facilities.  The frequency of the checks, the person
  responsible for each  check (with necessary back-up assignments)
  the review mechanism  in the QC program to be followed,  the
  frequency of the review and the corrective actions to be
  taken are specified.   A copy is provided to  each  analyst.

Part V of EPA Publication EPA-600/8-78-017 describes the
normal day-to-day microbiology inter!aboratory QC routine,
to be implemented by Region V microbiology laboratories.
A record is to be maintained of the daily QC checks and
procedures,  if there is no proof of performance, and
evidence for future reference, for practical purposes,
no QC program is in operation.

o A Sample Log shall be maintained which records,                 I
  chronologically, information on sample identification           •
  and origin, the necessary chain of custody information,
  and analyses performed.                                         •

o A Written Record shall also be maintained of all  analytical
  QC checks: positive and negative culture controls, sterility    •
  checks, replicate analyses by an analyst, comparative data       I
  between analysts, use-test results  of media, membrane
  filters and laboratory pure water,  replicate analyses done
  to establish precision of analysts, or of methodology used       •
  to determine non-compliance with bacterial limits established   |
  by Agency regulations.

Aquatic Biology Inter!aboratory Quality Control                   I
Interlaboratory QC procedures for aquatic biology programs
are fully described in  EPA Publication, EPA-679/4-73-001.
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                          An operating manual shall be prepared, addressing the
                          following essential elements as a minimum:


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 1.   An understanding and acceptance of the importance
      of quality control  (QC)  and a commitment on the
      part of the biology staff to fully integrate QC
      practices into field and laboratory operations.

 2.   Staff needs with adequate formal  training and
      experience and proper specialization to meet
      program needs.

 3.   Adequate field equipment, storage and laboratory space,
      instrumentation, and taxonomic references.

 4.   Protocol for preparation and design of field and
      laboratory studies.

 5.   Documentation of approved methodology, where available,
      and protocol for consideration of the tehcnical
      defensibility of the methods and their application.

 6.   Protocol for use of replication in sample collection
      and analyses where  feasible, and determination of the
      accuracy and precision of the data.

 7.   Protocol for frequent calibration of field  and
      laboratory instruments.

 8.   Protocol for proper sample identification and handling
      to prevent mi sidentification or intermixing of samples.

 9.   Protocol for blind, split, or other control samples
      to evaluate performance.

10.   Procedures for development and regular use  of in-house
      reference specimen  collections, and use of  outside
      taxonomic experts to confirm or provide identifications
      for problem specimens.

11.   Procedures for meticulous, dual-level  review of the
      results of manual arithmetical  data manipulations and
      transcriptions before the data are used in  reports
      or placed in BIO-STORET.

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                        68

  Organic Chemistry  Interlaboratory Quality Control                   |
  Most  of the  quality control  program described above in
  Section 8.7  of  this document cannot easily be adapted to            _
  the methods  for organic  compounds.  Therefore, the Agency           I
  has developed a series of tests and protocols whose purpose         ™
  is  to describe  the performance of the computerized gas
  chromatography  - mass spectrometry systems and the analysts(s).     •
  The complete protocol procedure is listed in Appendix 16.           I
  A summary of these performance tests follows:

  I.  Spectrum Validation  Test - Uses decafluorotriphenyl             I
     phosphine  (DFTPP) to deteremine whether the system gives
     a 70  ev  electron ionization fragmentation pattern similar
     to that  found  in the historical mass spectrometry data          I
     base, and the  required mass resolution and natural              •
     abundance isotope patterns.  The spectrum of DFTPP must
     meet  the criteria given  in Table 2 of Appendix 16.              •

 II.  System Stability Test -  Uses DFTPP to test moderate term
      (20-28 hours)  system stability.  The criteria given in          _
     Test  I must be met.                                             I

III.   Instrument  Detection Limit Test - Uses DFTPP to measure the
     full  and valid spectrum  detection limit at a defined and        •
     tolerable noise level.   At a signal/noise = 5, the              |
     required instrument  detection limits are 50 nanograms
     for systems used in  the  anlaysis of industrial or municipal     _
     wastes,  and 30 nanograms for systems used in the analysis       I
     for ambient or drinking  water.                                  ™

 IV.  Saturation  Recovery  Test - Uses DFTPP and _p_-bromobiphenyl       •
     to simulate a  frequently encountered situation with             I
     real  samples.  The spectrum of DFTPP, measured within
     two minutes after the elution of a 250 fold excess of           •
     j>bromobiphenyl, must not contain significant contributions     I
     from  the ions  attributable to j>bromobiphenyl.                  m

  V.  Precision Test - Uses a  variety of typical environmental        I
      pollutants  to  determine  precision from filling a syringe        •
     to peak  integration.  The mean relative standard deviation
     for the  compounds used in the test which elute as narrow        •
      peaks must  be  7% or  less using either peak areas in             |
     arbitrary units or ratios of peak areas.  For broad
      peaks the mean relative  standard deviation must be 13%
     or less.                                                       •
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                          69

  VI.   Library Search Test - Uses data  from Test  V  to  evaluate  the
       speed and completeness of the minicomputer library  search
       algorithm.  The mean search time,  including  background
       subtraction, must be one minute  or less,  and all  test
       compounds must be identified as  most probable except
       isomers with very similar spectra  should  not be counted
       as incorrect.

 VII.   Quantitative Analysis with Liquid-Liquid  Extraction - Uses
       a variety of environmental pollutants to measure  quantitative
       accuracy and precision of the total  analytical  method.
       The mean of the means of the percentages  of the true
       values observed must be in the 68-132% range with a
       mean relative standard deviation of 38% or less using
       either internal or external standards. This test also
       evaluates laboratory performance.

VIII.   Quantitative Analysis with Inert Gas Purge and  Trap - Uses a
       variety of compounds to measure  quantitative accuracy and
       precision of the total analytical  method.   The  mean of
       the mean method efficiencies must  be 70%  or more.
       Chloroform efficiency must exceed  90% and  all compounds
       must exceed 30% efficiency.  The spectrum  of j>bromofluoro-
       benzene must meet the criteria given in Table 7,  Appendix 16.
       The mean of the means of the percentages  of  the true
       values observed must be in the range of 90-110% with a
       mean relative standard deviation of 19% or less using
       either internal or external standards.

  IX.   Qualitative Analysis with Real Samples -  Uses a real sample
       to evaluate the ability of the system to  deal with  real  sample
       matrix effects and interferences.   All compounds  must
       be correctly identified except isomers with  nearly
       identical mass spectra should not  be counted as incorrect.
       This test also evaluates laboratory performance.

   X.   Solid Probe Inlet System Test (Optional)  - Uses cholesterol
       to evaluate the spectrum validity  achievable with a
       solid probe inlet system.  The spectrum of cholesterol
       must meet the criteria given in  step three of the test.

   The performance tests are intended for use in  the evaluation
   of the system initially and on a long  term basis.   All
   tests are to be initially performed  with correction being

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made to meet the criteria established in Appendix  16  for           I
the respective test.   The results  and corrections  are to be
documented.                                                        •

Test I performance is to be revalidated on  a  daily basis.
Test IV, V, VII, VIII, and IX performance are to be revalidated
on a specified frequency identified in the  documented intra-        I
laboratory QC protocol.                                            •

The normal day-to-day (£ routine is divided into three separate     •
categories.  Data generated from each category is  documented.       |
Problems identified must be corrected and documented.  When
out of control situations occur, analyses shall  be stopped         _
until the problem has been identified and resolved.                I

The first category represents the  determination  of purgeable
compounds.  This determination is  performed in a closed            •
analytical system; the complete analysis can  be  performed          |
in 1 h; and the number of theoretically possible interferences
is somewhat limited.   The second category represents  liquid/liquid •
partition methods in a regulatory  situation.   Here a  very          I
limited number of compounds are being measured;  there is a
high occurrence of positive results; and it is important to
establish that the method works satisfactorily on  the particular   •
sample matrix.  The third category represents liquid/liquid         I
partition methods in a monitoring  situation.   Here a  large
number of compounds are often being measured  simultaneously;        •
there is a low occurrence of positive results; and each sample      I
matrix may be different.  Quality  assurance is aimed  at
establishing that the laboratory is using the method  correctly.

The purgeable methods are unique among organic methods because      •
the standards are treated in exactly the same way  as  the samples,
and there is no inherent method bias.  The  methods are amendable   •
to a variety of quality assurance  programs.  The approach          |
that has been found applicable to  all types of samples and
provides the maximum data for the  expended  effort  consists         m
of the addition of one or more internal standards  to  the           I
matrix before purging.  Data generated in this program             ™
provide a continuous monitoring of the equipment and  establishes
matrix applicability for the test.                                  •

For liquid/liquid extraction methods in a regulatory  situation,
the emphasis is placed on duplicates and dosed samples.  Both       •
field duplicates and laboratory duplicates  are used in the         •
program to establish sampling and  subsampling validity.            ™
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                                    71

             The dosing of samples  to establish  method  accuracy  for the
             matrix is an integral  part  of this  program.  Where  the
             analytical program will extend over a  long period of time
             the construction of control  charts  is  recommended.

             When the liquid/liquid extraction methods  are  used  for monitoring,
             the emphasis is  placed on an external  control  series.  A standard
             laboratory matrix is developed.  With  each series of samples the
             matrix is dosed  and analyzed with the  samples.  Data generated
             over a period of time  can be used to monitor the performance
             of the equipment and the analyst, with relatively tight
             specifications to define problems that arise.  Control
             charts can be constructed to alert  the analyst to problems,
             but there is no  provision for rejection of results  for
             samples of this  type.

  8.7.2  Inter-laboratory Quality Control  Procedures
         An inter-laboratory  quality control  program serves to select and
         evaluate methods, characterize  their precision and accuracy, and
         provide data for evaluating both laboratory and analyst performance.
         Specific objectives  of this program are to:

         o Measure the precision of reproducibility of  methods of analysis
           within various programs.

         o Identify interference in different sampling  environments.

         o Measure the precision and accuracy of results between laboratories.

         o Provide a mechanism for  evaluation and/or certification of lab-
           oratories and analysts.

         o Detect weak, improper, or impractical  methodology.

         o Detect training needs and upgrade laboratory performance.

         o Assist laboratories or programs in obtaining new resources.

         The inter-laboratory quality control program is referred to as the
         Accuracy and Performance Audit* Programs by the Quality Assurance Office,
         Region V.  This program was briefly referred to in Section 4.2.1.

*Audit - A check made by the  QAO or its  representative  to determine the
         reliability of a specific  step  in a measurement.   For example, a
         check on the flow of a Hi-Vol air sampler,  the sensitivity of a
         spectrometer detector and  the ability to analyse a blind unknown
         sample are all audits.
*System Evaluation - An on-site inspection and review of the total quality
         assurance and quality control program.   The inspection  will be
         made by the QAO or its representative.

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                                     72
             Standards.  Materials which have assay values which have been
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8.7.2.1  Management of the Accuracy and Performance Audit  Programs
         The number of programs in water,  waste,  air and  special  projects
         are several.   The number of measurement  parameters  which are
         utilized in these several  programs  are  numerous.  QAO presently
         manages this program by manual means.   All data  is  evaluated
         manually, which requires a considerable  amount of time.  As soon
         as the last Milestone on page 7 of  this  document  is met  the              •
         QAO will manage an audit program utilizing ADP programs  which  will       |
         provide the needed level of audits  that  will assure quality data
         adequate for the requirements of the data  user.                          _

         The areas of activities which are covered  under  this audit program       •
         are described below:

         1.  Audits are to be performed according to frequencies  and              |
             procedures  required by Federal  Regulations,  EPA Guidelines
             or Region V Policy (e.g., air audits shall conform to  the            _
             requirements of 40 CFR Part 58,  Appendix A and  B).   The scope       I
             of audit must be determined for each measurement parameter          *
             (analyte).  A performance audit for the measurement  of a
             given analyte in drinking water would  be carried our by mailing     •
             a reference sample to a laboratory.  The reference sample            •
             would contain the analyte in a  concentration  known to  QAO,
             but unknown to the analyst.  The analyte would  be measured          m
             and the value reported back to  QAO.  A similar  type  audit            I
             would be performed for sewage treatment plants, laboratories
             analyzing water from lakes and  streams, etc.  On the other
             hand, an audit of a Hi-Vol Sampler  would require an  individual       I
             going to a sampling site, measuring  flow rates  using two or         I
             more reference plates and examine the  equipment for  maintenance
             and operating conditions, recording  temperature, pressure  and       •
             other information.                                                  jj

         2.  Audit materials are available from  EMSL-Cinci nnati,  EMSL-RTP,
             EMSL-LV and commercial sources.   Audit materials may be prepared    I
             as needed by QAO in conjunction with Central  Regional  Laboratory    •
             and/or contractors.  A repository of reference  materials will
             be maintained by QAO for special substances,  substances obtained    •
             by contract and from other sources  when not  available  from          |
             EMSL.  A central reference file will be developed which can
             be accessed by Automatic Data Processing (ADP).  This  file          _
             will give the facility providing the reference  material, the         I
             concentration or weight per unit and method  used to  establish       "
             reference value.  Reference materials  will be referenced to the
             highest standard available, preferably to National Bureau  of         •
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    verified by Best Available Technology (BAT)  are  referred  to
    as SRM's and those which have been assayed by NBS  are NBS-SRM.
    Federal  Regulations and EPA Guidelines will  be followed in
    determination of the appropriate SRM.  Other materials will
    be measured by BAT and designated as reference samples.

3.  Studies will be conducted as specified in QAO's  program plan
    to accomplish certain objectives relative to audits,  reference
    materials, and methods.  Determination of the "true value" of
    an analyte is at time tenuous.  Only an estimate of the "true
    value" can be made for some analytes.  The determination  or
    estimation of the value for a reference material  will be
    derived from collaborative testing.   These studies will use
    data from studies such as:

    a.  The methodology within the International  Joint Commision
        (IJC) group of analytic systems is not uniform and various
        methods may be used to measure a given analyte.  The
        results for a reference material analyzed by a variety of
        methods will be less predictable and the estimate of
        "true values" less precise.   The studies must  discern the
        overall reliability of the methods and identify methods
        which tend not to measure the analyte.  Studies will  be
        used to establish procedures which are uniform for a  given
        measurement principal.  The data from such studies require
        statistical evaluation and at time sophisticated  matrix
        solutions.  These statistical evaluations will be processed
        on ADP.

    b.  Methods may be used which are not designated as reference
        or equivalent methods.  Methods for many analytes have not
        had suitable evaluations and accuracy is not known.
        Thus, studies will be made by QAO to provide data files
        on BAT when such information can be obtained.   Data files,
        data systems such as Comnet.  EMSL-Cincinnati , etc.,  will
        be accessed through a Tektronix 4014 terminal.

    c.  Laboratories will be evaluated by performance audits  and
        system evaluations which will include methodology, calibration,
        training, maintenance and other operations.   Audit data and
        production records will  provide a measure of the  effectiveness
        of the quality control program.

4.  Independent audits for determination of measurement accuracy
    will be managed by QAO.  The individuals performing audits may
    be located at the Region V,  QAO or in the various  S&A district

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                            74

    offices.  The audit procedures will  be prepared by QAO or if       I
    audits are performed by personnel  other than QAO those procedures
    will be approved by QAO.                                           •

State and local  agencies will  develop  their audit procedures.
Conformance with Federal Rgulations and EPA Guidelines will be         —
determined by QAO.  Audit procedures must be reviewed by the           I
appropriate agency on an annual  basis  and revised as appropriate.       •
Revisions must be approved by QAO.

Each instrument will require an independent audit performed by a       |
State agency, Region V or by contract.  The frequency of audits is
to be based on requirements of regulations, EPA guidelines or          _
Region V policy.                                                       I

Some audit results may be reported by  ADP terminal  as soon as ADP
is functional, to QAO for storage in suitable data  files.  These
audit reports would provide date, time, auditor, analyte, method,
instrument (reference method, equivalent non-equivalent), agency
name, site number, temperature, pressure, all pertinent technical
data and values observed.  A written report to the  agency and the
respective Region V media program manager will be made indicating
acceptability of performance and/or corrective action required
and expected time required to meet compliance.

The operating agency will acknowledge  corrective action and reply
by indicating that corrective action was taken or would be completed
by a given date.  Where corrective action can not be made with
existing equipment, intended action must be indicated.  The QAO
will review the operating agency response for acceptability.

A re-audit will be scheduled by QAO and effectiveness of
corrective action verified.  Verification will be made by an
appropriate QAO staff member or appropriate auditor and reported
to QAO.

The final audit report is written up and reported formally.  The
time of reporting will conform to the  QAO program plan requirements.
The recipient of the audit report is the operating  agency with copies
sent to the respective media program manager.

Reports of unacceptable audits sent to the QAO will automatically
be flagged for the particular instrument.  Data will be invalidated
or held in storage as invalid until corrective actions are completed.
This system will improve on the data analysis over the present system
because audits are not presently correlated with the data until after

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summaries have been prepared.   Thus,  it  is  necessary  to  go  backwards
and delete invalid date at a later date.  There  has not  been  a
systematic method for correlating audits  with  site data.

Types of instrument audits which will  be  made  are:

a.  Ozone calibration audits.   These  are  resource intensive since
    a calibration system must  be maintained with strict  quality
    control measures.  The method of  measurement must be by the
    reference method.  The audit requires transporting a primary
    calibration or a transfer calibrator  to a  monitoring site.
    Multi-level calibration checks are made which may require as
    much as 3 to 4 hours operating time.  These  audits will be
    performed by auditors located in  the  district offices and
    verified by QAO, or performed by  QAO.

    Audit results for all systems in  the  Region  are correlated to
    estimate a "true value" to define accuracy of ozone  measure-
    ments in Region V.

    Frequency of ozone audits  and the acceptable limits  are
    defined in 40 CFR 53, Appendix A.  State and local agencies
    will be audited with a minimum number of audit frequencies
    described in the Appendix  A of the regulations.   Greater
    frequencies are encouraged to the limit of cost effectiveness.
    Present auditing levels in Region V  are greater than the
    minimum required in proposed regulations.  These  levels of
    audits are considered justified since they improve cost
    effectiveness.  Quicker turn around time on  audit reports
    and improved operations might suggest a lesser frequency, but
    demonstration of the appropriate  levels will result  from  the
    evaluations established in this program.

b.  Hi-Vol Sampler audits are  resource intensive requiring  travel
    to monitoring sites, measurement  of several  flow  rates  and
    evaluation of operations and equipment. Personnel who  audit
    the Hi-Vol Samplers are from the  District  Offices.  Audit is
    verified by the QAO.  Frequency of audits  are determined  by
    QAO based on regulations,  EPA guidelines or  Region V policy.
    Hi-Vol Samplers are audited by Region V, State and local
    agencies on a frequency which is  greater than that required by
    40 CFR 53, Appendix A.  Acceptable limits  applied in Region V
    are tighter than required  by Appendix A.

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             Audit reports  are  transmitted  to the QAO  for  verification.
             A copy of the  report  will be provided  to  the  Agency  audited
             and to the appropriate  media program manager  in Region V.
             The report records temperature, pressure,  unusual  instrument
             findings, site number,  Agency  name  and two or more observed
             flow rates using reference  plates.  Reference plates are
             calibrated by  equipment which  has been referenced  to the
             highest standards  available.

         c.  Calibration equipment:  QAO  will procure,  operate and maintain
             calibration equipment required for  all measurement parameters.
             Procedures, specifications, operation  manuals, maintenance
             manuals and spare  parts lists  will  be  compiled for use with
             this equipment and made available for  Regional, State and
             local agency use/or information from the Central Reference
             Files.  List of vendors will be documented for ready reference
             in order to expedite  replacement of equipment.  Calibrations
             will be made on various instruments for measurement  of critical
             pollutants, particularly continuous monitors.  QAO will maintain
             quality control records on  these instruments.

         d.  Audits on detector sensitivity for  spectrometers,  pH meter
             accuracy, etc., will  also be made on an instrument-by-instrument
             basis.

8.7.2.2  Management of the  On-Site System Evaluation of Total In-House,
         Federal, State and Local  Agency, Contractor,  Grantee Monitoring
         Program

         The Quality Assurance  Office has total  responsibility  for managing
         the system evaluation  program.  A  system evaluation is an on-site
         inspection and review of  the quality control  program used for the
         total measurement  system  for each  specific monitoring  program
         conducted by a Federal, State or local  agency.  For convenience,
         some items that each quality control plan  must contain (discussed
         elsewhere in this  document) and which will be evaluated  are repeated
         below:

         1.  Organization and Responsibility - Is the  quality control
             program operational?

         2.  Sample Collection  - Are written procedures available for sample
             collection and are these followed as documented?

         3.  Sample Analysis -  Are written  analysis procedures  available
             and are procedures followed as written?

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4.  Data Validation - Is a list of criteria for data validation
    available and it it used?

5.  Calibration - Are written calibration procedures available and
    are procedures followed as written?

6.  Performance Evaluations - Are control charts for performance
    evaluations reviewed and corrections made when indicated?

7.  Intralaboratory Tests - Are results from intralaboratory testing
    reviewed and corrections made when indicated?

8.  Preventive Maintenance - Is the preventive maintenance schedule
    being followed as recommended in the QA plan?

The results of the system evaluation is documented by the QAO
for presenting a visual picture of the performance of the program
to see if the minimum requirements of the Region's Quality Assurance
Plan are being met.  If not, deviations are identified and
recommendations made for corrections.  If corrections are not
made, recommendations are made to the appropriate program director
for action (eg., withholding grant or contract funds, etc.).

Appendix 17 depicts how the system evaluation program will  function.

A system evaluation will be conducted at all laboratories in
Region V funded by EPA engaged in the Clean Water or Clean Air Act,
the Safe Drinking Water Act, the Toxic Substance Control  Act,  and
other pertinent Acts.  All parameters analyzed for, will  be evaluated.
The minimum QC elements for these laboratories for several  major
programs are listed in Appendix 18 and 19 and will be evaluated
for compliance with these minimum requirements.  The minimum QC
elements for the above laboratories engaged in the Clean  Air Act
monitoring activities are listed in EPA publications 600/9-76-005,
600/4-77-027a, and 600/4-77-127b, "Quality Assurance Handbooks
for Air Pollution Measurement Systems", and 40 CFR Part 58, Appendix
A and B.  Laboratory evaluations will be based on compliance with
minimum requirements contained in these documents.

The on-site evaluation programs will be administerd as separate
operations.  These will be evaluations of the:

a.  State principal laboratories and offices (water and wastewater).

b.  State principal laboratories and offices (air).

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                                 78

     c.  Local  laboratories  analyzing  public  water  supply  samples.

     d.  Local  air agency offices.

     e.  Contract laboratories.

     This division of work is  required because  of the  administrative
     separation of the programs.

DATA PROCESSING

The term "data  processing" is  used to  include handling,  validation,
verification, transmission and storage,  and  reduction, including
software QC  considerations as  described  below.  Just as  samples and
specimens can be destroyed,  data  can be  lost, distorted, misinterpreted,
incorrectly transcribed,  improperly  transposed, overlooked,  or subject
to other distortions, unless suitable  QC  procedures are  used to protect
its integrity.

To obtain meaningful  environmental data,  the  representative  sample
must be delivered unchanged  to the analyst who  will develop  the
needed data by  performing the  prescribed  analysis.  The  completed
(i.e., calculated) results need verification  calculations  to eliminate
outliers or extraneous results and the conversion of acceptable results
to some final form for permanent  recording of the analytical  data in
meaningful exact terms.  These results are then transferred  to a data
storage facility for future  interpretation and  use.  All quality
control plans must document  the mechanism to  deal with those requirements
listed in 9.1.  9.2 and 9.3.   Those mechanisms shall be as  stringent as
those specified below.

9.1  Data Handling Transmission and  Storage
     Measurements of the  concentration of pollutants,  either in the
     ambient environment  or in the emissions  from stationary sources,
     are assumed to be representative  of the  conditions  existing at
     the time of the sample  collection.   The  extent to which this
     assumption is valid  depends  on  the  sources of  error and bias
     inherent in the collection,  handling, and  analysis  of the sample.

     Besides the sampling and  analytical  error  and  bias, human error
     may be introduced any time between  sample  collection  and sample
     reporting.  Included among the  human errors are such  things as
     failure of the operator/analyst to  record  pertinent information,
     mistakes in reading  an  instrument,  mistakes in calculating results,
     and mistakes in transposing data  from one  record  to another.

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Data handling systems involving the use of computers  are  susceptible
to keypunching errors and errors involving careless handling  of
magnetic tapes and other storage media.  Although  it  cannot be
completely avoided, human error can be minimized.

Data reporting techniques and error sources depend on the type of
sensor measurement system.   Measurement sensors  for pollutant
concentration may be classified by their sample  collection principle
into two categories:  (1) Integrated,  and (2) Continuous.  Pollutant
measurement systems may be either integrated or  continuous, whereas
ambient measurement systems are normally always  continuous.

In the integrated sample collection principle, a discrete sample
is collected in some medium and is normally sent to a laboratory
for analysis.  The sampler, field operator and the laboratory
analyst can make errors in data handling.

In the continuous sample collection principle, an  analytical  sensor
produces a direct and continuous readout of the  pollutant concentration
parameter.  The readout may be a value punched or  typed on paper
tape or recorded on magnetic tape.  In addition, some continuous
measurements systems may also use telemetry to transmit data  to a
data processing center.  Both human and machine  errors can occur
in data handling in this type of system.

a.  Data errors in integrated sampling - For ambient  monitoring,
    the sampler or operator records information  before and after
    the sample collection period.  For source emission testing,
    the operator records information during the  sample collection
    period in addition to before and after it.   Acceptance limits
    should be set for data pertaining  to flow rates,  etc., and
    the operator/analyst should invalidate or "flag"  sampling
    data when values fall outside these limits.  Questionable
    measurement results may indicate the need for  calibration or
    maintenance.

    The analyst in the laboratory reads measurements  from balances,
    colorimeters, spectrophotometers,  and other  instruments;  and
    records the data on standard forms or in laboratory notebooks.
    Each time values are recorded, there is a potential for incorrectly
    entering results.  Typical  recording errors  are transposition
    of digits (e.g., 216 might be incorrectly entered as  126) and
    incorrect decimal point location (e.g., 0.0635 michg  be entered
    as 0.635).  These kinds of errors  are difficult to detect.
    The supervisors must continually stress the  importance of
    accuracy in recording results.

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    Acceptance limits  contained  in the measurement method write-up      •
    and those shown  in the method activity matrix should be used
    by the analyst to  invalidate or  "flag" analysis data when           •
    values fall  outside these  limits.                                   |

b.  Data errors  in continuous  analyses - Continuous monitoring          _
    systems may  involve either manual or automated data recording.      I
    Automated data recording may involve the  use of a data logging      m
    device to record data on paper tape or magnetic tape at bench
    or the remote sampling station,  or the use of telemetry to          I
    transmit data on-line to a computer at a  central facility.          I

    Manual reduction of pollutant concentration data from strip         •
    charts can be a  significant  source of data errors.  In addition     I
    to making those  errors associated with recording data values
    on record forms, the individual  who reads the chart can also
    err in determining the time  average value.  Usually the reader      •
    estimates by inspection the  average  concentration.  When the

    temporal  variability in concentration  is  large, it  is difficult
    to determine an average concentration.  Two  people  reading
    the same  chart may yield results  that  vary considerably.
I
    Persons responsible for reducing  data  from  strip  charts  should      _
    be given training.   After a  person  is  shown how to  read  a           •

    chart, his/her results  should be  compared with those of  an          •

    experienced analyst.  Only after  he/she has demonstrated the

    capability to obtain satisfactory results should  a  analyst  be       •
    assigned to a data  reduction activity.                              |


    Periodically the senior analyst or  section  chief  should  check       _

    strip charts read by each analyst.                                  •


    Up to 10 percent of all  data reported  by each analyst  is to
    be checked by the Quality Assurance Coordinator for errors.         •
    If an individual is making gross  errors, additional training        |
    is to be provided.


    Because manual chart reading is a tedious operation, a drop        I

    in productivity and an  increase in  errors might be  expected
    after a few hours.   Ideally, and  individual should  be  required

    to spend only a portion of a day  at this task.                      •


    The use of a data logging device  to automate data handling

    from a continuous sensor is  not a strict guarantee  against          •

    data recording errors.   Internal  validity checks  are necessary      I

    to avoid serious data recording errors.  There are  two sources
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                        81

of error between the sensor and the recording medium:  (1)  the
output signal from the sensor and (2) the errors in recording
by the data logger.

The primary concern about the sensor output is to ensure that
only the sensor analog signal and not electronic interferences
be converted to a digital readout.  Internal  validity  checks
should be planned to "flag" spurious data resulting from
electronic interferences.

For a system involving the use of telemetry,  it is also necessary
to include a validity check for data transmission.

Errors in computations - To minimize computational errors,
operators and analysts should follow closely the formulae,
calculation steps, and examples given for each method, using
the calculation instructions and forms provided in the method
write-up.

The senior analyst should check the computations of each analyst.
Up to 10% of all data reported computations are to be  checked
by the QA Coordinator for errors.

Control charts - Procedures for reviewing data at the  operational
as well as the managerial levels.are to be implemented by data
generators (lab and field).  Review of measurement results
from control samples used during analysis, for example, can
indicate out-of-control  conditions that would yield invalid
data from subsequent analyses, if the conditions are not
corrected immediately.  At the managerial level, periodic review
of data can indicate trends or problems that  need to be addressed
to maintain the desired level of precision and accuracy.  One
common tool for statistical analysis of data  at both the
operational and the managerial levels is the  control chart.
The major steps in constructing the control chart were outlined
in Section 8.7.1.

The control chart provides a tool for identifying the  systematic
variation (assignable cause) from the system  indeterminate
variation (random).  This technique displays  data in a form
that graphically compares the variability of  all test  results
with the average or expected variability of small groups of
data.

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The steps to consider in the application  of control  charts          I
are the following:

1.  Select critical  characteristics in  the  measurement  system  to    I
    audit.

2.  If audit (reference) standards  are  used, obtain  the necessary   I
    materials.                                                      •

3.  Select the data  quality objective to  audit:                     •

    a.  Precision -  A measure of mutual agreement  among
        individual measurements  of  the  same property, usually       —
        under prescribed similar conditions.                       I

    b.  Accuracy - The difference between an average value
        and the true value when  the latter  is known  or  assumed.     •

4.  Choose the audit size and frequency:

    a.  Size - i.e., for air analysis,  the  analysts  will  often be   I
        dealing with samples of  2,  which  will form most subgroups.  ™

    b.  Frequency of subgroup sampling  -  Changes  are detected  more
        rapidly as the sampling  frequency is increased.  Audit
        rates of 7-10 percent are recommended for many
        characteristics shown in the method activity matrices.

5.  Set control limits,  Control limits (CL) are  to  be  set  at
    2 times the standard deviation  for  P

6.  The control charts are to be maintained either by the
    operator/analyst or the supervisor.   The control chart
    should be kept  up to date.   The QA  coordinator is to
    review the charts on some established frequency. After
    establishing 15  to 20 data points,  the  control limits
    should be reestablished on the  basis  of these data.  If
    the new control  limits are narrower than those recommended,
    the former is to be used. After this initial  calculation,
    control limits  should be recalculated every 3 to 6  months,
    or whenever significant data trends or  shifts become
    obvious.
    The control chart is actually a graphical  presentation of
    quality control effectiveness.   If the procedure is
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    "in control", the results will  almost  always  fall  within
    the established control  limits.   Further,  the chart  will
    disclose trends and cycles from assignable causes  that
    can be corrected promptly.

Report Forms - The analytical  information  reported should
include the measured parameters;  the details of the analyses
such as burette readings, absorbance, wavelength, normalities
of reagents, correction factors,  blanks; and the  reported
data values.  To reduce errors in manipulation of numbers
a general rule is to reduce  handling and transposition of
date to an absolute mini num.  Ideally, a report form includes
preliminary information about the sample and its  analysis,
and the same form is used for the final  reporting form for
entering of data into a computer.  However, if such a  set-up
is not available the protocol  below is to  be used to record
finali zed data.

1.  Loose Sheets - Reporting of data onto  loose or ring-binder
    forms is a means of recording data that allows easy  addition
    of new sheets, removal of older data,  or collection  of
    specific data segments.   However, the  easy facility  for
    addition or removal also permits loss  or misplacement of
    sheets, mixups in date sequence, and ultimately questionable
    status of the data for formal display  or presentation as
    courtroom evidence.  Loose sheets are  not  encouraged.

2.  Bound Books - The use of bound books is an improvement
    in data recording that tends  to result in  a chronological
    sequence of data insertion.  Modification  beyond a simple
    lined book improves its  effectiveness  with little  additional
    effort.  Numbering of pages encourages use of data in
    sequence and also aids in referencing  data through a
    table of contents ordered according to time,  type  of
    analysis, kind of sample,  and identity of  analyst.

    Validation can be easily accomplished  by requiring the
    analyst to date and sign each analysis on  the day  completed.
    This validation can be strengthened further by providing
    space for the laboratory supervisor to witness the date
    and the completion of the analyses.

    A further development of the  bound notebook is the
    commerically available version  designed for research-type
    work.  These notebooks are preprinted  with book and page
    numbers, and spaces for  title of project,  project  number,

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                        84

    analyst signature,  witness  signature,  and  dates.   Each
    report sheet has  a  detachable  duplicate  sheet that  allows
    up-to-date review by management  without  disruption  of the
    notebook in the laboratory.

    Bound notebooks can and  should be  used in  routine
    analytical laboratories.  The  need for repeated  information
    on sampling and analyses  can be  answered by  use  of  preprinted
    pages in the bound  notebook.

Preprinted Report Forms - Most  field laboratories and
installations repetitively analyzing fixed parameters  develop
their own system of compiling laboratory data  that may  include
bound notebooks, but  a  means  of forwarding data  is also required.
Usually, laboratories design  forms to  fit  a  related  group of
analyses or to report a single  type  of analysis  for  a  series
of samples.  As much  information as  possible is  preprinted  to
simplify use of the form. With loose-sheet, multicopy  forms
(using carbon or FCR  paper)  information can  be forwarded on
the desired schedule  while also allowing retention of  data  in
the laboratory.  Still, the  most common means  for recording
data in rough form are  internal bench  sheets or  bound  books.
The bench sheet or book never leaves the laboratory  but serves
as the source of information  for transfer  of data to appropriate
report forms.

In most instances the supervisor and anlayst wish to look at
the data from a sampling point  or  station  in relation  to other
sampling points or stations  on  or  in a particular AQCR, river
or lake.  This review of data by the supervisor  prior  to
release is a very important  part of  the QC program of  the
laboratory; however,  such reviews  are  not  easily accomplished
with bench sheets.  For review  purposes, a summary sheet can
be prepared that displays a  related  group  of analyses  from  a
number of stations.  The form should contain space for all  of
the information necessary for reporting data,  the completed
form can also be used to complete  the  data forms forwarded  to
the computer storage and retrieval system.

The forms used to report to  storage  systems  provide  spaces
for identification of the sampling point,  the  parameter code,
the type of analysis  used, the  reporting terminology.   Failure
to provide the correct  information can result  in rejection  of
the data, or insertion  of the data into incorrect parameter
fields.  As sample analyses  are completed, the data  values
are usually reported  in floating decimal form  along  with the
code numbers for identifying the parameter data  fields  and
the sampling point data fields.
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4.  Plastic-Coated Labels and Forms -  A recent addition  to  good
    sample handling and data management is the availability of
    plastic-coated (blank or preprinted)  labels,  report  forms,
    and bound report books.   These materials are  waterproof, do
    not disintegrate when wet or handled, can be  written on while
    wet, and retain pencil or waterproof ink markings  though
    handled when wet.

5.  Digital Readout - Instrumental  analyses, including automated,
    wet-chemistry instruments such as  the Technicon  Auto Analyzer,
    the atomic absorption spectrophotometer, the  pH  meter,  and the
    selective electrode meter, provide digital readout of concen-
    trations, which can be recorded directly onto report sheets
    without further calculation.  Programmed calculators can be
    used to construct best-fit curves, to perform regression
    analyses, and to perform a series  of calculations  leading to
    final reported values.

6.  Keypunch Cards and Paper Tape - Because much  of  the  analytical
    data generated in laboratories is  first recorded on  bench
    sheets, then transferred to data report forms, keypunched,
    and manipulated on small terminal  computers (or  manipulated
    and stored in a larger data storage system),  there is a danger
    of transfer error that increases with each data  copy.   The
    analyst can reduce this error by recording data  directly from
    bench sheets onto punch cards that can be retained or forwarded
    immediately to the data storage system.  Small hand-operated
    keypunch machines are available.

7.  Automated Laboratory Systems - The use of digital  readout,
    keypunch cards, and paper tape have been overshadowed by the
    development of customized, fully automated online  computer
    systems that make measurements, calculate results, perform
    qulaity control, and report analytical  data simultaneously
    from a full range of laboratory instruments.   Such systems
    can contain the following functions:

    a.  Manual or automatic sampling and testing  of  a  series of
        samples, standards,  replicates and check  samples.

    b.  Detection of the measurement signals from the  series of samples,

    c.  Conversion of signals to concentrations,  generation of a
        standard curve, and calculation of sample values in final
        units.

    d.  Calculation of the deviation and recovery values of the
        results and indication of acceptance or nonacceptance
        based on limits established by the analyst.

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                                86

         e.   Provision  of  the  output in a form designated by the analyst:
             dial,  paper recording chart, digital readout, cathode ray
             tube,  or printed  report form.

     The degree of  hands-on  operation  required in the system is specified
     by the  analyst.

     If an automated  system  is properly designed and operated, most
     calculation and  transposition errors are avoided and the proper
     level of quality control  is automatically exerted.

9.2  Data Validation  and Verification
     Data validation  is the  process whereby data are filtered and
     accepted or rejected  based on a set of criteria.  This involves
     a critical review  of  a  body of data in order to isolate and locate
     spurious values.   It  may  involve  only a cursory scan to detect
     extreme values or  a detailed evaluation requiring the use of a
     computer.   In  either  situation, when a spurious value is located,
     it is not immediately rejected.   Each questionable value must be
     checked for validity.   Records of values that are either judged
     invalid or are otherwise  suspicious should be maintained.  These
     records are, among other  things,  a useful source of information for
     judging data quality.   Validation methods can be manual or by
     computerized techniques.

     a.  Manual - Both  the analyst and the laboratory supervisor should
         inspect integrated  environmental quality monitoring data.
         At  regular intervals, daily or weekly, results should be
         scanned for  questionable values.  This type of validation is
         most sensitive to extreme values, i.e., either unusually high
         or  low concentrations.  These are sometimes called outliers.

         The criteria for  determining  an extreme value are derived from
         prior data obtained at the particular sampling site (or a similar
         site if no previous data are  available for a site).  The data used
         to  determine extremes may be  the minimum and maximum concentrations'
         for all prior  data  from a site.  The decision criteria might
         also be based  on  minimum and  maximum for each season, each
         month, or each day.

         An  audit level of 7-10 percent should be established for
         checking data, i.e.,  checking 7-10 out of every 100 values.

     b.  Computerized Techniques - A computer can be used not only to
         store and  retrieve  data but also to validate data.  Any
         system for checking extreme values in manaul techniques also

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                        87

apply here.  The criteria for extreme values  can  be  refined
to be specific for individual  hours during  the  day.   For
example, with this procedure, an hourly average concentration
for carbon monoxide of 15 ppm may not be considered  an  extreme
value for 8:00 a.m. but could be tagged as  questionable if it
appeared at 2:00 am.

Another indication of possible spurious data  is a large difference
in concentrations reported for two successive time intervals.
The difference in concentrations, which might be  considered
excessive, may vary from one time to another  for  the same
pollutant.  Ideally this difference in concentration is
determined through a statistical analysis of  historical data.
For example, it may be determined that a difference  of  0.05
ppm in the S02 concentration for successive hourly averages
occurs rarely (less than 5 percent of the time).   But at the
same station the hourly average CO concentration  may change
by as much as 10 ppm.  The criteria for what  constitutes an
excessive, change may also be linked to time of  day and  pollutant
relationships, e.g., high concentrations of S02 and  03  can
not co-exist and these data should be considered  suspect.

Criteria for Determining Acceptability of Data  -  Reading strip
charts is a tedious job subject to varying  degrees of error.
A procedure for maintaining a desirable quality for  data
manually reduced from strip charts is important.   One procedure
for checking the validity of the data reduced by  a analyst is
to have another analyst or the supervisor check the  data.
Because the values have been taken from the strip chart by
visual inspection, some difference in the values  derived by
two individuals can be expected.  When the  difference exceeds a
specified amount and the initial areadi ng has been determined
to be incorrect, an error should be noted.  If  the number of
errors exceeds a predetermined number, all  data for  the strip
chart are rejected and the chart is read again  by a  technician
other than the one who initially read the chart.   The question
of how many values to check can be answered by  applying one
of two techniques.

1.  Application of Acceptance Sampling Techniques -  Acceptance
    sampling can be applied to data validation  to determine the
    number of data items (individual  values on  a  strip  chart)
    that need to be checked to determine with a given probability
    that all the data items are acceptable.   The  supervisor
    wants to know, without checking every data  value, if a
    defined error level  has been exceeded.  From  each strip

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    chart with N data values,  the  supervisor can  randomly           I
    inspect n data values.   If the number of erroneous  values
    is less than or equal to c, the rejection criteria,  the
    values for the strip chart are accepted.   If  the  number
    of errors is greater than  c, the values  for the strip
    chart are rejected,  and another analyst  is asked  to  read        _
    the chart.                                                     •

2.  Sequential Analysis  Test Procedure -  The typical  approach
    used in performing a statistical  test of hypothesis
    requires the collection of a sampTe of a fixed size.   A
    statistic is then computed from the sample data and  compared
    with some critical values  for  that statistic.  A  decision       _
    is then made to accept  the hypothesis (H0) or to  accept         I
    some a-1 tentative hypothesis (HI).   With  such  a procedure        •
    it is necessary to collect the specified sample of  observations
    regardless of the results  that may be obtained from  the         •
    first few observations.                                        I

    Sequential analysis  requires that a decision  be made           .
    after each observation  or  group of observations.  This         I
    procedure has the advantage that, on  the average, a  decision    •
    can be reached with  fewer  observations than a fixed  sample
    size requi res.                                                 •

Data Validations Procedures and Criteria  for the  Agency's
National Aerometric Data Bank  (NADB)                                •

The NADB is a computer storage and retrieval  system for
aerometric data collected by Federal, State  and local air  agencies.

40 CFR Part 58.35 specifies the NAMS data submittal requirements    I
to NADB which are 1 si ted below:
    The requirements of this section apply only  to those
    stations designated as NAMS by the network description
    required by §58.30.

    The State shall  report quarterly to the Administration          «
    (through the appropriate Regional  Office)  all  ambient air
    quality data and information specified by  AEROS Users           •
    Manual (EPA-450/2-76029, OAQPS No. 1.2-039)  to be coded         |
    into the SAROAD  Air Quality Data forms. Such  air quality
    data and information must be submitted on  either paper          _
    forms, punched cards, or magnetic tape in  the  format of         I
    the SAROAD Air Quality Data forms.                             •
                                                                  I

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                        39

c.  The quarterly reporting periods  are January  1-March  31,
    April 1-June 30, July 1-September 30,  and  October 1-December 31,
    The quarterly report must:

    1.  Be submitted within 90  days  of the end of  each  reporting
        period, and

    2.  Contain all data and information gathered  during the
        reporting period.

d.  The first quarterly report  will  be due on  or before
    June 30, 1981, for data collected during the first  quarter
    of 1981.

e.  Air quality data submitted  in the quarterly  report must
    have been edited and validated so that such  data  are
    ready to be entered into the SAROAD data files.   Procedures
    for editing and validating  data  are described  in  AEROA
    Users Manual (EPA-450/276-029, OAQPS No. 1.2-039).

f.  This section does not permit a State to exempt those
    SLAMS which are also designated  as NAMS from all  of  any of the
    reporting requirements applicable to SLAMS in  §58.26.

Highlights from the above documents  for data validation  are
described below:

1.  Screening Criteria - In order to draw correct  conclusions
    from the data, validity checks are built into  the data
    handling system.  The data  must  meet predetermined  standards
    with respect to representativeness, instrument averaging
    time, duration of sampling, and  comparability  before
    they are incorporated into  NADB.   A discussion of each
    criterion follows:

    a.  Representativeness - Data from each monitoring  site
        should characterize ambient  levels in  an area or
        neighborhood.  For example,  a daily average of carbon
        monoxide calculated from values collected  only during
        the morning rush hour would  hardly reflect the true
        daily averages.   The data must be  relatively  complete
        over the time interval  of interest (for  example,  day,
        season, or year) so that such biases can be avoided.

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                    90

b.  Instrument Averaging Time -  The data must represent  a       I
    sample interval  of 1 hour or more.   Thus, no more
    than 24 values per day per pollutant are  stored.            •
    Data for intervals of less than 1  hour are converted       •
    to hourly averages before storage.

c.  Duration - The data must be collected over a time  period   I
    of no less than 3 consecutive months so that at  least       •
    quarterly summary statistics can be calculated.
d.  Comparability - Aeromatic data must be maintained  in
    consistent units to permit data submitted by various
    agencies to be combined into nationwide summaries  and       _
    evaluation reports.  The data must have been acquired       I
    by application of standard methodologies.                  "

These four criteria are pertinent to developing meaningful      •
information from the data collected from any monitoring network^

Criteria for Completeness.   The raw data entering the  NADB      M
are checked for completeness (representativenesss).   With       •
continuous measurement, the criterion for completeness is
that at least 75 percent of the total  possible number  of
observations be present.  Figure 9.2 presents the number       •
of observations required by the NADB before summary  results    I
are calculated.

The data within the NADB resulting from intermittent sampling  I
are summarized only if there are at least five samples
per quarter.  An additional stipulation is that if a
month contains no samples each of the other 2 months in        I
the quarter must contain at least 2 samples.  Any other        •
distribution of samples over the quarter is acceptable.
This is a minimum criterion based on a random biweekly
sampling schedule.  A more stringent criterion should  be
applied when the sampling schedule is every third or
sixth day.                                                     —

Criteria for Accuracy and Precision - Accuracy and precision   •
data reported with aerometric data are not used to validate
data before entry into NADB but are used to interpret  the       •
data.                                                          |

Criteria for Handling Data Values below Minimum Detectable      •
Limits - Concentrations below the limit of detection of        I
the instruments employed result in the problem of determining  *
how to report such values so that summary statistics can
                                                               I

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                      Continuous measurement criteria  for completeness
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   Time interval
   Minimum number of observations
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3-hour running average
8-hour running average
24-hour
Monthly
Quarterly
Yearly
3 consecutive hourly observations
6 hourly observations
18 hourly observations
21 daily averages
3 consecutive monthly averages
9 monthly averages with at least
  two monthly averages per quarter
               Figure 9.2   Criteria  for completeness  for  continuous ambient
                            air monitors for NADB

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                        91

    be calculated.   The choice  of data  values  is  complicated by
    the fact that zero, the most  likely value  to  be  supplied,
    cannot be used, especially  if geometric  parameters  are to
    be calculated.

    This problem is handled by  inserting a constant, approxi-
    mately equal to one-half the  minimum detectable  limit,
    for each method and analysis  technique.  This value was
    chosen after examining  the  lower end of  the cumulative
    distributions for the various pollutants.  Seldom did the
    log-normal  distribution (the  distribution  most often
    applied to air pollution data)  accurately  describe  this
    portion of the data.  This  may be due in part to the
    existence of a background level  for each pollutant.  Use
    of the midpoint between zero  and the detectable  limit as
    the substitute value for concentration levels below the
    detection threshold seems reasonable.  In  order  to  permit
    consistency from year to year,  one  minimum detectable
    value is used for each  pollutant even if the  minimum
    detectable limit is changed,  unless there  is  a change by
    an order of magnitude.   Figure 9.2.1 provides an example
    of the current minimum  detectable limits as used by the
    NADB for each pollutant and the value to be inserted for
    each value below the minimum  detectable  limit.   These
    minimum detectable limits are reviewed periodically and
    changed as required.  Each  laboratory should  determine
    its own set of minimum  detectable limits,  based  on  its
    own analytical  techniques and instruments, to generate
    pollutant information.

    One additional  point should be mentioned concerning the
    use of substituted values for values below the threshold
    of the method.   When more than 25 percent  of  the measured
    levels are below the minimum  detectable  quantity, no
    statistics are computed from  the data.   This  contraint guards
    against the possibility of  biasing  the computed  statistics.
    Furthermore, at least 50 percent of the  measurements in a
    set of data must be above the minimum detectable concentration
    before a frequency distribution of  the values can be
    prepared.

5.  Criteria for Handling Data  with Negative Values  - For the
    purpose of generating true  pollutant values,  negative
    pollutant concentrations imply  that there  is  not enough
    of the pollutant present for  the instrument to detect

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                                 92

             above the noise  limit specified  for the  instrument.             |
             When negative values occur, they should  be  regarded as
             being below the  detection  limit  for the  method and treated      »
             in the same manner,  i.e.,  assigned a  value  one-half the         I
             minimum detectable limit.                                       ™

9.3  Data Reduction (Including Software QC Considerations)                   •
     The effectiveness of the quality assurance program  will  be              I
     determined by monitoring improvements in the  reliability
     of reported QC  data.   On a regular basis, the QAO will critically       •
     evaluate all reported QC data for  each reporting unit.   It is           I
     believed that this approach  will provide a data  base to  more
     accurately evaluate and  improve measurement performance.  The QAO
     will use a number of statistical techniques and  ADP to measure          I
     performance, which are briefly described below.  These techniques       B
     have been reviewed extensively elsewhere in this document.

     a.   Summary Statistics  - Summary  statistics  such as the mean           |
          and the standard deviation will be  used  to  simplify the
          presentation of data and at the same time to summarize essential   _
          characteristics.                                                  •

     b.   Frequency distributions - Frequency distributions such as
          normal and log-normal distributions will be used to present        •
          relatively large data sets, such as the  daily  concentrations       |
          of suspended particulates in  ambient air over  a long period
          of time, i.e., six  months.                                         •

     c.   Estimation and testing  procedures - Statistical estimation         *
          and testing procedures  will be used to make inferences
          concerning the conceptual population of  measurements made          •
          under the same conditions based on  a small  sample of data.         I
          An example would be the estimation  of the average pH of a
          large number (population) of  filters based  on  a sample (lot)       M
          of pH readings for  seven filters.                                  •

     d.   Outliers - Outliers, i.e., unusally large or small  values,
          are identified by appropriate statistical tests for outliers.      •
          These statistical tests are useful, for  example, in identifying    •
          gross errors in data handling procedures.

     e.   Audit data - Statistical methods for treating  performance          |
          audit data and for  presenting the results in terms  of bias
          and precision will  be used.

     f.   Replication, repeatability, and reproducibility tests - The        •
          identification of sources of  measurement error within and
                                                                           I

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                                      93

               among  laboratories  is  one  of the important functions of the
               Quality Assurance Office.   Statistical methods will be used
               to identify  these measurement  errors.

          Quality control audit data  from up  to 50  laboratories using
          several hundred different methods to monitor several hundred
          different  contaminants must be  monitored  on a continuing basis.
          This workload requires extensive use of computer technology and
          considerable skill  in interpreting  the results.  The statistical
          software package  that has been  identified in the description of
          needs,  once developed and implemented will be able to handle this
          large volume of data and generate reports that describe data
          quality in  non-technical language for the data users.  Reports
          will also  be produced for laboratory and  field personnel describing
          their performance relative  to that  of other groups using similar
          measurement procedures.  It is  intended that these reports will
          generally  be in a graphical  format  and include a listing of all
          supporting  results.

          The QAO data files  will  be  protected in the ADP system per the
          file protection protocol for the ADP system.  Files will not be
          accessible  to other offices.  Programs will be stored as "Declared
          Files". The original documentation of the software programs will
          be placed  in the  permanent  files of the QAO in case there is ever
          a need  to  refer back to  this documentation.  Updated print-outs
          will also  be maintained  on  all  file data  in case the data is lost
          due to  some hardware malfunction of the ADP system.

10.   CORRECTIVE ACTIONS

     Corrective actions are of two types:

     a.   On the spot  or immediate  - This  is the process of correcting
         malfunctioning equipment.

         In a quality assurance program,  one  of the most effective means
         of preventing trouble is  to  respond  immediately to reports from
         the operator of suspicious data  or equipment malfunctions.  Application
         of proper corrective actions at  this point can reduce or prevent
         the collection of  poor quality data.  Established procedures for
         corrective  actions are available in  the methods if the performance
         limits are  found to  be exceeded  (either through direct observation
         of the parameter or  through  review of control charts).  Specific
         control  procedures,  calibration,  pre-sampling or pre-analysis
         operational  checks,  etc., are designed to  detect instances in

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which corrective action is necessary.   A check-list  for logical          •
alternatives for tracing the source of a sampling  or analytical
error is provided to the operator.   Trouble  shooting guides              •
for operators (field technicians  or lab analysts)  are generally          |
found in instrument manufacturer's  manuals.   On-the-spot
corrective actions routinely made by field technicians or lab            _
analysts should be documented as  normal  operating  procedures,            I
and no specific documentation other than notations in operations         •
logbooks need to be made.  However, logbooks are to  be made
available to QAO for review during  any audit or on-site                 •
system evaluation.                                                      J

Long-term Corrective Action - The purpose of long-term corrective        _
action is to identify and eliminate causes of nonconformance or          I
noncompliance with Agency QA requirements,  Hopefully, they              •
will be eliminated permanently.   To improve  data quality to
an acceptable level and to maintain data quality at  an acceptable        •
level, it is necessary that the  quality assurance  system be              I
sensitive and timely in detecting out-of-control or  unsatisfactory
conditions.  It is equally important that, once the  conditions of        M
unacceptable data quality are indicated, a systematic and timely         •
mechanism is established to assure  that the  condition is reported
to those who can correct it and  that a positive loop mechanism
is established to assure that appropriate corrective action              I
has been taken.  A system of reporting deficiencies  and                 I
verifying corrective actions identified during the audit and
on-site sytem evaluation process  has been identified earlier             m
in this document and will not be  repeated here.                         g

1.  Closed-loop Corrective Action System for Major Problems -
    Experience in Region V has been that most problems will              I
    not disappear until positive  action has  been taken by               •
    management.  The significant  characteristic of any good
    management system is the step that closes the  loop—the              •
    determination to make a change  if the system demands it              |
    (this is mandated by the Agency's QC requirements and QA
    regulations).                                                       —

The following discussion outlines the considerations and procedures      •
necessary to understand and implement an effective closed-loop
corrective action system for major  problems.  Effective                 •
corrective action occurs when many  individuals and media                I
programs cooperate in a well planned program.  There are
several essential steps that must be taken to plan and implement         •
a corrective action program that  achieves significant results.           I
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                                 95

      Corrective actions should be a  continual  part  of  the  laboratory
      system for quality, and  they should  be  formally documented.
      Corrective action is not complete  until  it  is  demonstrated that
      the action has effectively and  permanently  corrected  the  problem.
      Diligent follow-up is probably  the most  important  requirement of
      a successful  corrective  action  system.

      Figure 10.1 illustrates  the sequence of activities  involved
      in operating a closed-loop corrective action system.

10.1  QA Management
      Sections 1 and 8.7.2 describes  the management  responsibility
      for Region V's Quality Assurance Program.   Feedback channels
      are identified for keeping informed  of  the  performance  of all
      monitoring systems in Region V  funded by EPA.  Procedures are
      also identified to monitor the  performance  of  the monitoring
      systems.  Elements of the program  have  been developed from the
      QAO Functional Statement, Agency Regulations and  requirements
      which serve as the foundation of Region  V's policy  statement,
      have been approved by the Regional Administration, making this
      program binding on the Region.  Goals have  been identified (including
      resources) to accomplish the objectives  of  this program.

10.2  QC Management
      Each monitoring activity shall  document  and implement a quality
      assurance policy approved by management  to  assure  that  sufficient
      quality control activities are  maintained to assure data
      credibility for each monitoring project.  Each monitoring project
      shall designate a Quality Assurance/control coordinator (preferably
      full-time) to be responsible for the environmental QC program,
      coordinators can be appointed for  specific  monitoring activities,
      i.e., Air coordinator, water coordinator.

      a.  Qualifications
          1.  The coordinator  should  have  as  a minimum  a bachelor's
              degree in physical  science,  chemistry, biology  or microbiology,
              with at least five years of  experience in his respective
              discipline.  In  addition,  the coordinator must  have
              actively worked  in a environmental  quality laboratory
              for at least two years.  Experience in statistical quality
              control techniques and/or  academic  courses in mathematics
              and statistics is also  highly desirable.

          2.  The coordinator  maintains  close  liaison with  the
              appropriate EPA  Regional Analytical Quality Assurance
              Coordinator, and is responsible  for the overall quality

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                            96

        assurance  program  in his  laboratory.  The coordinator
        should report  to the appropriate level:  It is highly
        desirable  that this  function  not be subordinate to an
        individual  responsible  for direct conduct of sampling or
        analyses.   This arrangement is workable, however, if the
        individual  responsible  for sampling and  analyses maintains
        an objective viewpoint.   While the overall program workload
        will  determine whether  this position is  a full-time or
        part-time  responsibility, it  should, in  most cases be
        full-time.

b.  Duties and Responsibilities
    The coordinator is responsible for developing and implementing
    an inter-and-intralaboratory  quality control program.  Specific
    duties include, but are  not necessarily limited to:

    1.  Participating  in the overall  quality control plan.
        This  includes  all  elements of the sampling and analytical
        programs.   The coordinator carries out this activity
        within EPA quality control and methodology guidelines.
        Other recommended  and accepted procedures can be used to
        supplement these guidelines.

    2.  Administering  the  inter!aboratory quality control
        program as a continuing in-house activity to ensure the
        integrity  and  validity  of analytical data.

    3.  Measuring  the  precision and/or accuracy  of analytical
        results.   Providing  on-line quality control of samples,
        i.e., reference samples,  duplicates, control charts,
        spiked, and audit  samples.

    4.  Providing  a permanent record  of instrument, and analyst
        performance as a basis  for evaluating data.

    5.  Identifying training needs and technical methodology
        gaps.

    6.  Upgrading  the  overall quality of laboratory performance
        by recommending procedural and personnel changes, as required,
        to ensure  the  validity  and integrity of  the data.

    7.  Coordinating the inter-and-intralaboratory quality control
        program with the QAO, Region  V, and other governmental and
        commercial laboratories.  This involves  participating in

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                                      97

                  round-robin  methodology  studies,  providing  quality control
                  check  samples,  and performance  of check  samples to requesting
                  laboratories.

              8.   Evaluating  and  discussing  the results  of activities
                  outlined in  Paragraphs 1 through  7 with  the appropriate
                  individuals  involved.  When  an  analysis  is  out of control
                  or a discrepancy is noted, the  coordinator  should be
                  notified and appropriate corrective action  should be
                  taken.

          c.   Competence  of Personnel
              The coordinator  should develop a training  program to
              ensure a minimal level of  proficiency.   He must recognize
              variations  in ability and  provide training to ensure that
              professional skills are appropriate to the task.  Training
              programs should  be  administered  in  order to  develop that
              level  of competence which  is necessary to  carry out assigned
              functions.   Moreover, these  programs  should  be  carried out in
              full cooperation with EPA  Region V, Quality  Assurance Office.

          d.   Basic  facility  and  Equipment Requirements
              The coordinator  should establish basic requirements
              (equipment, proper  facilities, etc.)  for operating an
              environmental laboratory.  These requirements should not be
              included as part of the quality  assurance  budget.  Laboratory
              facilities  should provide  an environment free from atmospheric
              contaminant levels  which can affect the desired analyses.
              The laboratory  should be clean,  air conditioned and/or heated,
              and have a  well  lighted work area.  Safety features and
              other  facilities consistent  with opeational  requirements
              should be  provided.

          e.   Initial  On-Site  Laboratory Evaluation
              The coordinator  will  implement his  planned quality assurance
              program with an  initial  on-site  laboratory evaluation.
              Subsequent  performance of  analysis  on audit  samples and
              participation in split sample  program with the  EPA regional
              office should also  be required.

11.    DATA QUALITY ASSESSMENT

        The assessment of data quality is  the  end result in a comprehensive
        QC/QA program.  Data quality assessment has four basic components:
        1) accuracy, 2)  precision,  3)  completeness, and  4)  representativeness.

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                              98

Each of these items is quantifiable  and  when  suitably  combined  can
produce a numerical coefficient which  is numerically proportional to
data quality.

A complete assessment of data quality, in terms  of the four
components, is not possible at this  time.   However, this  is  the
primary goal  of this QA effort.   Air data is  more  advanced that
water and wastewater data at this time for such  a  comprehensive
assessment of data quality.  However,  with the implementation of
this plan during FY 80, a numerical  assessment will be factored
into the FY 81 QA program plan activity.  The primary  key in this
activity is to get all quality control programs  developed, approved
and implemented.

The four basic components of data quality assessment have been
elaborated on in great detail and their  requirements are  listed
elsewhere in this document, but will be  summarized below.

11.1  /CCUR&Y ASSESSMENT

      The QA Plan shall require that the accuracy  of environmental
      data be determined and reported  provided that certified
      reference materials are available  or that  measurements can
      be traceable to a national  standard.

11.2  PRECISION ASSESSMENT

      The Region V QA Plan requires  that the  precision of
      environmental data be determined on a routine basis and
      reported to the suitable management authority as spelled  out
      in the QA and QC Management Section of  this  document  (11.1 -
      11.2).

11.3  COMPLETENESS ASSESSMENT

      The Region V QA Plan requires  that the  completeness of
      environmental data be assessed on  a routine  basis and  reported
      to the suitable management  authority based on approved methodology.
      Where the method is unapproved an  alternate  test procedure
      approved by the Regional Administrator, shall be used.  In
      certain specific cases where methodology does not exist,  the
      QAO will request EMSL to specify a methodology for  the Agency's
      use.

11.4  REPRESENTATIVENESS ASSESSMENT

      The Region V QA Plan requires  that the  representativeness of
      environmental data be assessed on  a routine  basis and  reported

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                                      99

              to the suitable management  authority  using  approved  method-
              ology.  Where the method is unapproved,  the same  protocol
              specified in 11.3 is  to be  followed.

        11.5  OVERALL DATA QUALITY  ASSESSMENT

              Overall data quality  assessments  are  to  be  included  with
              each data report for  water  and wastewater at the  start  of  FY
              81.   The overall data quality assessment for air  data is
              presently being reported.

12.    DATA QUALITY REPORTS (QC AND  QA)

      The following types of QC, QA reports are to  be  prepared  by  each
      monitoring group. These reports serve as  a indicator of the  monitoring
      group's progress in implementing its Quality  Assurance Program, which
      monitor the various subunits1  performance of  quality control procedures
      and achievement of quality assurance goals.

      1.  Analytical reports.  To maintain the  required flow of QA and QC
          information within a monitoring group, individual analysts, operators
          and laboratories need to  prepare QC reports  on  their  monitoring-
          and measurement activities.  These reports are  forwarded to the
          QA coordinator, who then  writes a QA  report  for the entire  laboratory
          organization.

      2.  Field Location reports.  QD data for  remote  monitoring sites
          must be developed and transmitted, either individually or grouped
          by location (i.e., sectional or regional), to the QA  coordinator.

      3.  Instrument inspection, calibration and maintenance reports.  How
          the instruments used in monitoring or measurement procedures are
          inspected and maintained  should be explained in a report to the
          QA coordinator.

      4.  Reference materials and standards reports.   The reference materials
          used and standards followed must be stated.   These reports  should
          cover not only, for example, the purity of chemical reagents,
          but biological materials  (such  as a discussion  of the availability
          of a particular plant needed in experiments)  as well.

      5.  Training reports (personnel).   Who was given quality  assurance
          and/or quality control  training? Did this training take place
          in-house? How much did this training  cost?   The training reports
          will answer these questions.

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                                     100

      6.   Certification  reports.  These reports will be generated only
          for the  public water  supply laboratory certification program.
          The procedures for  performance evaluation and certification of
          both laboratories and personnel will be detailed in these reports.

      7.   Quality  assurance reports.  Reports detailing the unit's quality
          control  and  quality assurance activities should be published on
          a quarterly  basis.

      Distribution of  and follow-up to these reports for corrective action
      will be the  same as that  described for all other types of  reports
      described elsewhere in,this document.

13.    CHAIN OF CUSTODY

      The following procedures  have been used successfully, and  are
      presented as suggested  procedures insofar as they fulfill  the legal
      requirements of  the appropriate State legal authority.

      a.   Procedures
          Quality  assurance should be stressed during all compliance
          monitoring and when reviewing self-monitoring programs, no matter
          what the reason for the spot check or inspection.  Successful
          implementation of a compliance monitroing program depends heavily
          on the capability to  produce valid data, and on clearly demonstrating
          such validity.  No  other environmental monitoring area requires
          more rigorous  adherence to  validated methodology and quality
          control  measures.

          It is imperative that laboratories and field operations involved
          in collecting  primary evidence prepare written procedures.  These
          procedures should be  used whenever evidence samples are collected,
          transferred, stored,  analyzed, or destroyed.  A primary objective of
          these procedures is to create an accurate written record which can  be
          used to  trace  possession of the sample from the time it is collected
          through  its  introduction into evidence.

      b.   Preparing Samples
          The evidence-gathering portion of a survey is characterized by an
          absolute minimum number of  samples required to give a  fair
          representation of the effluent or water body sampled.  The quantity
          and location of samples are determined before the survey.

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    Prepare chain-of-custody record  tags  before  actual  field  survey
    work.   Ensure tags  contain  all possible  information to minimize
    clerical  work by field  personnel.   Also  write the source  of each
    sample on the container before starting  any  field survey  work.

    Field  logsheets used  to document field procedures and chain-of-
    custody,  and to identify samples,  should be  pre-filled in to the
    extent practicable  to reduce  repetitive  clerical field entries.
    The sampler or project  leader should  maintain custody during
    sampling, using the logbook.  Any  information from  previous
    studies should be copied (or  removed) and filed before the logbook
    is returned to the  field.

    Follow explicit chain-of-custody procedures  to maintain the
    documentation necessary to  trace sample  possession  from the time
    the sample is taken until the evidence is introduced into court.
    A sample  is in your custody if:

    o It is in your physical  possession;  or

    o It is in your view, after being  in  your physical  possession; or

    o It was  in your physical possession  and you locked it in a

      tamper-proof container or storage area.

    All survey participants should receive a copy of the study plan
    and should be familiar  with its  contents before the survey begins.
    A pre-survey briefing should  be  held  to  inform all  participants
    of the survey objectives, sample locations and chain-of-custody
    procedures.  After  all  chain-of-custody  samples are collected, a
    debriefing should be  held in  the field to verify that chain-of-custody
    procedures have been  followed, and to determine if  additional
    evidence  samples are  required.

c.  Collecting Samples

    1.  Ensure that the smallest  possible number of people handle
        the sample.

    2.  Obtain stream and effluent samples using standard field
        sampling techniques.  When using  sampling equipment,  assume
        it is in the custody of the  source being sampled.

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                           102

3.  Attach chain-of-custody record  tag  to  the  sample container
    when the complete sample is  collected.   Ensure the container
    has the following information:  sample  number, time taken,
    date taken, source of sample (include  type of sample  and
    name of firm),  preservative,  analyses  required, name  of
    person taking  sample, and witnesses.   The  front side  of the
    card (which has been prefilled)  is  signed, timed, and dated
    by the person  doing the sampling.   Tags  must be legible and
    filled out in  ballpoint (water-proof ink). Secure individual
    sample containers or group of sample containers using a tamper-
    proof seal.

4.  Take blank samples.   Include one sample  container without
    preservative,  and containers with preservatives.  The laboratory
    will analyze these contents  to  verify  that no containers are
    contaminated.

5.  Maintain an up-to-date Field Data Record Logbook.  Record
    field measurements and other pertinent information necessary
    to refresh the sampler's memory if, later  on, he takes the
    stand to testify regarding his  actions during the evidence-
    gathering activity.   Maintain a separate set of field notebooks
    for each survey; store them  in  a safe  place where they can
    be protected and accounted for  at all  times.  Standard formats
    have been established to minimize field  entries; these include
    the date, time, survey, type of sample taken, volume  of each
    sample, type of analysis, sample number, preservatives,
    sample location and field measurements (temperature,  conductivity,
    DO, pH, flow),  and any other pertinent information or observations.

    The field sampler signs the  entries.   The  survey coordinator
    is usually responsible for preparing and conserving the field
    logbook during the survey.   Once the survey Is complete,
    field logs will be retained  by  the  survey  coordinator or his
    designated representative, as a part of  the permanent record.

6.  The field sampler is responsible for the care and custody
    of the collected samples until  they are  properly dispatched
    to the receiving laboratory, or turned over to an assigned
    custodian.  The field sampler should verify that each container
    is in his physical possession or in his  sight at all  times,
    or is locked so that no one  can tamper with it.

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                               103

    7.   Colored slides or photographs  are  often  taken  to  show  the
        outfall sample location and any visible  water  pollution.
        Written documentation on the back  of the photo should  include
        the photographer's signature,  and  the time,  date,  and  site
        location.   These photographs can be  used as  evidence,  and
        are handled by chain-of-custody procedures to  prevent  alteration.

d.  Transfer of Custody and Shipment

    1.   When transfer!ng the possession of samples,  the transferree
        signs, dates, and times the reverse  side of  the chain-of-
        custody record tag or record.   Custody tranfers,  if made to
        a sample custodian in the field, are made for  individual
        samples.  The chain-of-custody tag or card must be dated and
        signed by the second person who takes custody.  If a third
        person takes custody, he must  follow the same  procedure.  An
        additional  chain-of-custody tag or card  is completed by
        persons who thereafter, take custody. It is apparent, from
        this chain, that the number of custodians should  be minimal.
        Additional  tags or cards should be numbered  consecutively.

    2.   If a custodian has not been assigned, the field custodian
        or field sampler is usually responsible  for  properly packaging
        and dispatching samples to  the proper laboratory  for analysis.
        In that case, the "Dispatch of Sample" portion of the  chain-
        of-custody record tag or card  should be  properly  filled out,
        dated, and signed.

    3.   Ensure that samples are properly packed  in shipping containers
        (for example, ice chests) to avoid breakage.   Ensure that shipping
        containers are padlocked for shipment to the receiving laboratory.

    4.   Include a "Sample Transmittal  Sheet" with all  packages.
        The original, and one copy  generally accompany the shipment.
        Mail copies directly to the laboratory,  to data management
        personnel,  and to any other responsible  agent.  The survey
        coordinator usually retains one copy.

    5.   If the package is sent by mail, ensure that  it is  registered
        with return receipt requested.   If package is  hand-delivered,
        record delivery in the logbook. Send receipts  from post
        offices and bills of lading to the laboratory  custodians for
        retention as part of the permanent chain-of-custody documentation.

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                           104

6.  When samples are delivered to  the  laboratory,  and  appropriate
    personnel  are not there to receive them,  samples should  be
    locked in a secure, tamper-proof area.   The  same person  must
    unlock the samples and deliver custody  to the  appropriate
    custodian.

LABORATORY CUSTODY PROCEDURES

The following procedures are to be used by  Region  V monitoring
activities to provide the chain of possession and  custody of any
sample offered for evidence, and for which  analytical  test
results amy be introduced into evidence in  any environmental case.

The primary objective of these procedures is  to  create an accurate
written record which can be used to trace the possession and
handling of the sample from the moment of collection through
analysis and its introduction as evidence.

1.  The laboratory director will designate  one full-time employee
    (usually the laboratory supervisor) as  a  sample custodian,  and  one
    other person as an alternate.   In  addition,  the laboratory  must
    provide a sample storage area  that is secure and can be  locked.

2.  All samples will be handled by a minimum  possible  number of
    persons.

3.  Only the custodian will receive incoming  samples.   If he is
    absent, the alternate will indicate receipt  by signing the
    sample transmittal sheets and, (as appropriate), the sample
    tags which accompany the samples.   The  alternate will retain
    the transmittal sheets as permanent records.

4.  The custodian shall ensure that heat-sensitive, light-
    sensitive samples, radioactive, or other sampe materials having
    unusual physical characteristics,  or requiring special handling,
    are properly stored and maintained prior  to  analysis.

5.  Distribution of samples to the section  chiefs  who  are
    responsible for the laboratory performing the  analysis
    shall be made only by the custodian.

6.  The laboratory area shall be maintained as a secured area,
    restricted to authorized personnel only.

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                               105

    7.   Laboratory personnel  are responsible  for the care  and custody
        of the sample once it is received  by  them  and  shall be  prepared
        to testify that the sample  was  in  their possession and  view
        or secured in the laboratory at all times  from the moment it
        was received from the custodian until  the  time that the
        analyses were completed.

    8.   Once the sample analyses are completed, the unused portion
        of the sample, together with all identifying labels, must be
        returned to the custodian.   The returned,  tagged sample,
        should be retained in the custody  room until permission to
        destroy the sample is received  by  the custodian.

    9.   Samples shall be destroyed  only upon  the order of  the
        Laboratory Director,  in consultation  with  previously designated
        Enforcement officials, or when  it  is  certain that  the information
        is no longer required or the samples  have  deteriorated.  The same
        procedure is true for tags  and  laboratory  records.

e.  EVIDENTIARY CONSIDERATIONS

    Reducing chain of custody procedures as well as the various
    promulgated laboratory analytical  procedures to writing will
    facilitate the admission  of evidence under rule 803(6) of the
    Federal Rules of Evidence (PL.  93-575).   Under this statute,
    written records of regularly conducted business activities may
    be introduced into evidence as  an exception to the "Hearsay
    Rule" without the testimony of  the  person(s) who made  the record.
    Although preferable, it is not  always  possible to  have the individuals
    who collected, kept, and  analyzed samples testify  in court.  In
    addition, if the opposing party does not  intend to contest the
    integrity of the sample or testing  evidence, admission under the
    Rule 803(6) can save a great deal  of trial time.   For  these
    reasons, it is important  that the procedures followed  in the
    collection and analyses of evidentiary samples be  standardized
    and described in an instruction manual which,  if need  be, can be
    offered as evidence of the "regularly  conducted business activity"
    followed by the lab or office in generating any given  record.

    In criminal cases however, records  and reports of  matters
    observed by police officers and law enforcement personnel are not
    included under the business record  exceptions  to the "Hearsay Rule"
    previously cited (see Rule 803(8),  P.L. 93-595).   It is arguable
    that those portions of the compliance  inspection report dealing

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                                    106

         with  matters  other  than  sampling and analysis results come within
         this  exception.   For  this  reason, in criminal actions records and
         reports  of matter observed by field investigators may not be
         admissible and  the  evidence may still have to be presented in
         the form of oral  testimony by the person(s) who made the record
         or report, even though the materials come within the definition
         of business records.   In a criminal proceeding, the opposing
         counsel  may be  able to obtain copies of reports prepared by
         witnesses, even if  the witness does not refer to the records
         while testifying, and if obtained, the records may be used for
         cross-examination purposes.

         Admission of  records  is  not automatic under either of these
         sections.  The  business  records section authorizes admission
         "unless  the source  of information or the method or circumstances
         or preparation  indicate  lack of trustworthiness," and the caveat
         under the public records exception reads "unless the source of
         information or  other  circumstances indicate lack of trustworthiness".

         Thus, whether or not  the inspector anticipates that his or her
         compliance inspection report will be introduced as evidence, he or
         she should make certain  that the report is as accurate and objective
         as possible.

14.   SPECIFIC  GUIDAFCE

     American  Public Health  Association, American Water Works Association,
          and  Water Pollution  Control Federation.  1975.  Standard Methods
          for the Examination  of  Water and Wastewater.  14th Edition.
          Washington,  D.C.

     American  Society  for Testing and Materials.  1978.  Annual Bood of
          ASTM Standards, Part 31:   Water.  Philadelphia, Pennsylvania.

     Bicking,  C., Olin,  S.,  and King, P.  1978.  Procedure for the Evaluation
          of Environmental Monitoring Laboratories.  U.S. Environmental
          Protection Agency, Environmental Monitoring and Support Laboratory,
          Office  of Research and  Development, Cincinnati, Ohio.
          EPA-600/4-78-017.

     Codified  Federal  Regulations:  40 CFR Part 35, 50, 51, 52, 53, 58,
          136, 141 and 250.

     Harris, D.J. and  Keffer,  E.J., June 1974.  Wastewater Sampling
          Methodologies  and  Flow  Measurement Techniques.  U.S. EPA,
          Region  VII,  Kansas City,  Missouri.  EPA-907/974-005.

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                               107

Kulin, Gershon.   May 1975.   A Guide to Methods  and  Standards  for the
     Measurement of Water Flow.   U.S.  Government  Printing  Office,
     Washington, D.C.   National  Bureau of Standards Special
     Publication 421.

Lauch, R.P.  April  1975.   Peformance of ISCO Model  1391  Water and
     Wastewater Sampler.   U.S. Environmental Protection  Agency,
     Cincinnati, Ohio.  EPA-670/4-75-003.

Lauch, R.P.  April  1975.   Application and Procurement  of Automatic
     Wastewater Samplers.  U.S.  Environmental  Protection Agency,
     Cincinnati, Ohio.  EPA-670/4-75-003.

Lauch, R.P.  September 1976.  A Survey of Commercially Available
     Automatic Wastewater Samplers.  U.S. Environmental  Protection
     Agency, Cincinnati,  Ohio.  EPA-600/4-76-051.

Linen, A.L.  1973.   Quality Control for Sampling  and Laboratory
     Analysis.  In:  The Industrial Environment—Its Evaluation  and
     Control, pp. 277-297.   U.S. Department of  Health, Education,
     and Welfare, Public Health  Service, Center for Disease Control,
     National Institute for Occupational Safety and Health.

Sherma, J.  1979 (1st revision).  Manual of Analytical Quality Control
     for Pesticides and Related  Compounds in Human  and Environmental
     Samples:  A compendium of Systematic Procedures Designed to
     Assist in the Prevention and Control of Analytical  Problems.
     Prepared for U.S. Environmental  Protection Agency,  Office of
     Research and Development, Health  Effects Research Laboratory,
     Research Triangle Park, North  Carolina.  EPA-600/1-79-008

Smoot, C.W.  November 1963.  Orifice Bucket for Measurement of Small
     Discharges from Wells.  Water  Resources Division  Bulletin,
     Illinois Water Survey, Champaign, Illinois.

U.S. Army.  Environmental Effects Laboratory.   May  1976.   Ecological
     Evaluation of Proposed Discharge of Dredged  or Fill Material
     Into Navigable Waters: Interim Guidance for  Implementation
     of Section 404(b)(l) of Public Law 92-500  (FWPCA  of 1972).
     U.S. Army Engineer Waterways Experiment Station,  Vicksburg,
     Mississippi.  Miscellaneous Paper D-76-17.

U.S. Department of Interior.  Bureau of Reclamation.   1974.   Second
     Edition, Revised.  Water Measurement Manual, U.S. Government
     Printing Office,  Washington, D.C.

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                               108

U.S. Environmental  Protection  Agency,   n.d.   EPA  Project Officer's
     Guide (Research  & Demonstration Grants).   U.S.  Environmental
     Protection Agency, Office of Planning  and  Management,  Office of
     Administration,  Grants  Administration  Division, Washington, D.C.

U.S. Environmental  Protection  Agency,   n.d.   Guidance  Package  for
     Evaluation of State Laboratories  (Source Sampling)—Draft.
     Cincinnati, Ohio.

U.S. Environmental  Protection  Agency.   1976.  Minimal Criteria and
     Procedures for the Evaluation  of  Ambient Air Monitoring
     Programs—Laboratory and  Field.   Draft III.

U.S. Environmental  Protection  Agency,  Enforcement Division.  Office
     of Water Enforcement.   Compliance Branch,  n.d.   NPDES Compliance
     Sampling Manual.   Washington,  D.C.   MCD-51.

U.S. Environmental  Protection  Agency.   Health Effects  Research Lab-
     oratory.  Environmental Toxicology Division.  1974, 1977  rev.
     ed.  Analysis of Pesticides Residues in  Human and Environmental        •
     Samples:  A Compilation of Methods Selected  for Use in Pesticide       |
     Monitoring Programs.  Edited by J.F. Thompson.  Research  Triangle
     Park, North Carolina.                                                  —

U.S. Environmental  Protection  Agency.   Office of  Research and  Development.  •
     Environmental  Monitoring  and Support Laboratory.  1976.   Quality
     Assurance Handbook for Air Pollution Measurement  Systems:             •
     Volume I—Principles.   Research Triangle Park,  North Carolina.         |
     EPA-600/9-76-005.

U.S. Environmental  Protection  AGency.   Office of  Research and  Development.  •
     Environmental  Monitoring  and Support Laboratory.  1977.   Quality       ™
     Assurance Handbook for Air Pollution Measurement  Systems:
     Volume 11--Ambient Air Specific Methods.   Research Triangle            I
     Park, North Carolina.   EPA-600/4-77-027a.                              I

U.S. Environmental  Protection  Agency.   Office of  Research and  Development,  m
     Environmental  Monitoring  and Support Laboratory.  1977.   Quality       I
     Assurance Handbook for Air Pollution Measurement  Systems:
     Volume Ill—Stationary Source  Specific Methods.   Research
     Triangle Park, North Carolina.  EPA-600/4-77-027b.                     •

U.S. Environmental  Protection  Agency.   Office of  Research and  Development.
     Environmental  Monitoring  and Support Laboratory.  1978.                •
     Environmental  Radioactivity Laboratory Intercomparison Studies         I
     Program, 1978-1979.  Las  Vegas, Nevada.  EPA-600/4-78-032.
                                                                           I

                                                                           I

                                                                           I

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                               109

U.S. Environmental  Protection Agency.   Office  of Research  and  Development.
     Environmental  Monitoring and Support  Laboratory.   1979.   Handbook
     for Analytical  Quality Control  in Water and Wastewater  Lab-
     oratories.  EPA-600/4-79-019.

U.S. Environmental  Protection Agency.   Office  of Research  and  Development.
     1978.  Manual  for the Interim Certification of Laboratories
     Involved in Analyzing Public Drinking Water Supplies, Criteria
     and Procedures.  EPA-600/8-78-008.

U.S. Environmental  Protection Agency.   Office  of Research  and  Development.
     Environmental  Monitoring and Support  Laboratory.   1979.   Methods
     for Chemical Analysis of Water  and Wastes.   Cincinnati, Ohio.
     EPA-600/4-79-020.

U.S. Environmental  Protection Agency.   Office  of Water  Planning and
     Standards.  Monitoring and Data Support Division and  Environmental
     Monitoring and Support Laboratory.  Minimal  Requirements  for a
     Water Quality Assurance Program,  Cincinnati, Ohio.  EPA-440/9-75-010,

Weber, C.I., ed.  1973.   Biological  Field  and  Laboratory Methods for
     Measuring the Quality of Surface  Waters and Effluents.  U.S.
     Environmental  Protection Agency,  National  Environmental Research
     Center, Office of Research and  Development,  Cincinnati, Ohio.
     EPA-670/4-73-001.

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                                                                                          1
cntral
cQional
aboratory
hiaf, Ross
                                   APPENDIX  3  (Continued)
                              SlF.VEILLAfiCE ft ANALYSIS DIVISION
                                    U.S. EPA - REGIOM V
                                     ORGANIZATION CHART
                  Director, Sanders
                  Deputy Dlr., Yeatcs
                  ArininistratiVQ Officer,
                 '  Johanssn
                                    Qua!ity
                                    Assurance
                                    Office
                                                       Chief, Adams
 Environmental
 Emergency
 Investigations
 Branch
Technical"
 Support
 Branch
Chief, Townsend
  Central
  District
  Office
Chisf, flog an
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Easter*
DistriJi
Office
Chief. Vacant   Chief, WLnkTliofc
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                                           APPENDIX 4
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I                                      STATE OF WIXONSIN
                               DEPARTMENT OF NATURAL RESOURCES
                                    BUREAU OF AIR MANAGEMENT
                                     AIR MONITORING SECTION
 •                                  QULITY ASSURANCE MANUAL

 |                                        PROCUREMENT

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                                                                      VJA O.^.JL.J.
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                                Procurement Testing Procedures
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The following guidelines are to be used when evaluating continuous
monitors prior to purchase.  These are not purchase specifications.
Articles relating to vendor responsibility and warranty obligations will
be included in purchase specification guidelines.  This is a description
of parameters that must be considered and tested when evaluating monitors
prior to purchase.

Pre-purchase instrument evaluation will consist of several parts:  1) a
preliminary elimination process based on data gathered by DNR concerning
user experience, vendor provided performance test results, and instrument
advantages and disadvantages; 2) equipment testing of instruments,
selected as a result of screening of data gathered in #1, to assure the
instruments perform as stated - this testing will be performed by DNR
personnel; and 3) final considerations of equipment usability in DNR's
network, vendor cooperation and desirable features, which will further
narrow down the number of instruments.  Monitors to be considered for
evaluation must have been designated by EPA as reference or equivalent
methods.  No equipment will be approved for purchase without first
having completed the evaluation process outlined here.  Final selection
of instruments to be purchased by DNR will be based on the degree to
which the monitor exceeds minimum specifications, the performance test
results, purchase and annual operations costs, and availability and cost
of service/repair by contract/demand.

NEED ANALYSIS

To begin the analysis, the DNR group undertaking the instrument evaluation
must prepare a needs analysis report which analyzes the application for
which the instruments will be used and determines which instrument
characteristics will best fit the application.  For example, will the
instrument be used for background monitoring (list the ambient levels
expected) or point source monitoring (expected ambient levels are higher).
The following parameter needs must be defined in this report:

          1.  expected concentration range
          2.  threshold concentration
          3.  anticipated gas stream composition
          4.  response time
          5.  maintenance requirements
          6.  portability requirements

This report is to be prepared and circulated to each DNR group who will
be affected by the instrument purchase, as well as to the Quality Assurance
Coordinator, for comments.  After comments are received and the report
revised, the specifications and user review can take place.

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SPECIFICATION AND USER REVIEW
                                                          QA 6.2.1.1             I
                                                          Revision &             •
                                                          Page 2 of 28

                                                                                 |
This phase of the evaluation is a weeding out process.   As we have    ^-^^       •
neither the manpower nor space for extensive instrument testing,  only a          •
small number of instruments will be chosen for such testing.   This
initial evaluation is to be the means of choosing which instruments will
be tested in-house.  If more than one measurement principle is listed as         I
a reference or equivalent method (as is the case with SO  continuous             I
methods) at least one instrument from each measurement principle must be
considered in this initial evaluation.  The following information must           •
be gathered for each instrument that is evaluated, and a report prepared         •
on the results of this data gathering phase.

     1.   Request instrument operating manuals from each manufacturer            I
          and review them.  Check and compare measurement principles,            I
          performance characteristics and relative complexity of operation.
          List advantages and disadvantages of each.                             •

     2.   User experience - The manufacturer will be contacted to supply
          a list of users.  EPA should also be contacted for names of
          any dissatisfied users.  Agencies or industries with prior             I
          field experience with each particular instrument will be               •
          contacted for their opinion of the instrument's mechanical,
          electronic and chemical dependability (confidence in instrument        •
          data), ease of working with the instrument, user experience            |
          with the vendor, vendor responsiveness, cost of operation, and
          instrument downtime.  At least two users must be contacted for
     .     each instrument evaluated.  Attached is a copy (Figure 1) of           •
          the questions to be covered when talking to the users.                 •

     3.   Performance testing - Manufacturer shall provide written               •
          results of their equivalency testing, to be evaluated for              |
          precision, accuracy, interferences, etc.

     4.   Vendor cooperation - Each vendor will be contacted and evaluated       I
          as to his/her:  a) willingness to comply with the terms of the         •
          pre-purchase arrangement (our in-hour testing) and purchase
          contract specs, b) factory and local representative expertise,        •
          support, and facilities, c) instrument warranty terms, d)             |
          willingness to supply all information required to operate,
          maintain and repair the instrument.             •                      _

     5.   Required support equipment - Determine what is needed in terms        •
          of supporting electronics, gas cylinders, etc., for each
          instrument evaluated, and the availability and cost of such.          •
          Which of these items do we already have, their adequacy and           |
          their age.  Which items must be purchased and the cost of the
          purchase should be included.                                          _
     6.   Annual operating costs - Approximate cost of parts, reagents,
          electronics, gas cylinders, manpower support, and a list of
          high and low motality parts for each instrument evaluated.
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                                                         QA  6.2.1.1
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     7.   Conformity of each instrument to existing DNR instrumentation
          systems (both the vans and the permanent continuous monitoring
          stations).

          a.   manifold .
          b.   data acquisition system
          c.   rack mounting
          d.   calibrators
                                                                     «

The information in the report will be organized into tables for purposes
of comparison; each parameter listed above is to be scored (based on its
relative importance as determined in the needs analysis) and a summary
chart of comparative scores will be drawn up.  These tables and charts
will be circulated for comment and recommendations to key persons within
the air monitoring program who are knowledgeable with instrumentation.
Any instrument or manufacturer not favorably rated in this phase of
evaluation will be excluded from further testing.  Recommendations for
no more than three instruments to be tested in depth in DNR labs, will
be made by representatives of each monitoring group and the quality
assurance coordinator.

INSTRUMENT TESTING
As a result of the specification and user review, up to three monitors
will be tested in-house by DNR personnel.

The purpose of this testing is to:

     1.   Obtain a working knowledge of each instrument - how easy it is
          to use, how well it performs, and what problems we might
          expect with it.

     2.   Verify that certain crucial equivalency testing parameters are
        •  indeed met;  Equivalency test results are provided to EPA by
          the manufacturer and are not verified by EPA.  Some users have
          found that the equivalent designated instruments that they
          have purchased are not meeting these performance specifications.

     3.   There are differences in instrument performance among instrument
          manufacturers whose instruments pass the equivalency specifications.
          Some instruments just pass the testing, while others have
          performance that is vastly superior to the equivalency specifications.

The following instrumental tests are to be conducted on all continuous
monitors being considered for purchase.  Figure 2 is an example of how
the results of the testing should be reported.

I.   Range

     A.   Definition
                                           -  -        es
          Nominal minimum and maximum concentrations which a method is
          capable of measuring.

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                                                         QA  6.2.1.1
                                                         Revision  i
                                                         Page  4  of 28
     B.    Test Procedure
          1.    Allow the instrument to warm up  as per manufacturer's
               instructions.

          2.    Construct a calibration curve showing the test analyzer's
               response over at least 95 percent of the required range.

          3.    Allow the instrument to run for  24 hours before performing
               any further tests.

II.  Noise Test

     A.   Definition

          Noise is the short-term deviation in output signal which is
          not the result of changes in input concentration.  It is
          essentially the standard deviation.  Noise is an inherent
        "  property of an instrument arising from imperfect electronics,
          mechanical stresses, quality of optics, etc.  Noise levels are
          critical as they set limits on useful measurement levels, and
         • the lower detectable limit is often defined as twice the noise
          level.

     B.   Test Procedure

          1.   Allow sufficient time for the test analyzer to warm up
               and stabilize.

          2.   Connect an integrating-type digital voltmeter  (DVM)
               suitable for the test analyzer's output, and accurate to
               three significant digits, to measure  the analyzer's
               output signal.  Also connect the analyzer to an  appropriate
               strip chart recorder.

          3.   Measure zero air for 60 minutes.   Use the range  setting
               specified in Table  I.  The  recorder  should be  set  for 0
               to 1 volt full  scale.  During this 60-minute  interval,
               record 25 readings  at  2-minute  intervals.

          4.   Convert  each DVM reading or strip  chart recording  to
               concentration  units (ppm) by reference to the test
               analyzer's  calibration curve.   Label the converted DVM
               readings r^, r£,  •  •  •»
           5.    Calculate the standard deviation,  S,  as follows:
                                   2 - 1/25 ^±)

                S (ppm)
                                  24

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                                                     QA 6.2.1.1
                                                     Revision <5
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     6.   Let S at zero ppm be So; compare So to the noise specification
          given in Table I.


     7.   Repeat steps (3) through (6) using a recorder output of
          either 0 to 1MV or 0 to 5MV.  The baseline on the strip
          chart should be at 50% of full scale, so that positive
          and negative deviations can be observed.  Compare S^y to
          the noise specification as given in Table I.


C.   Lower Detectable Limit


     Definition - The minimum pollutant concentration which produces
     a signal of twice the noise level.


     1.   Test Procedure


          a.   Allow sufficient time for analyzer to warm up and
               stabilize.  Measure zero air for at least 15 minutes
               and record the stable reading in ppm as BZ-


          b.   Generate and measure for at least 15 minutes a
               pollutant test atmosphere concentration equal to the
               value for the lower detectable limit specified in
               Table I.


          c.   Record the test analyzer's stable indicated reading,
               in ppm, as B^.


          d.   Determine the lower detectable limit (LDL) as LDL »
               Bl ~ BZ'  Compare BL - BZ to 2SO.

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QA 6.2.1.1
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1
•

1
Table I - EPA Performance Specifications for Automated Methods

Sulfur Photo- Carbon
Performance parameter Units dioxide chemical monoxide
oxidants
1. Range - Parts 0-0.5 0-0.5 0-50
per
million
2. Noise do ^ .005 .005 .50
3. Lower detectable
limit do .01 .01 1.0
4. Interference
equivalent
Each inter ferent do +.02 +.02 +1.0
Total interferent do .06 .06 1.5
5. Zero drift,
12 and 24 hour do +.02 +.02 +1.0
6. Span drift, 24 hour
20 percent of upper
.range limit Percent +20.0 +20.0 +10.0
80 percent of upper
range limit do +5.0 +5.0 +2.5
7. Lag time Minutes 20 20 10
8. Rise time do 15 15 5
9. Fall time do 15 15 5
10. Precision
20 percent of upper
range limit Parts
per
million .01 .01 .5
80 percent of
upper range limit do .015 .01 .5


1. To convert from parts per million to ug/m^ at 25°C and
multiply by M/0. 02448, where M is the molecular weight of

t
-
as
-
.

Nitrogen
dioxide

0-0.5

•
.005

.01

+0.02
.04

+.02

+20.0

+5.0
20
15
15


.02

.03


760 mm Hg,
the gas.




-





1





1





1





1

1





1
1
1
1
1
1
1

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III.  Zero Drift,  Span Drift,  Lag Time,  Rise Time,  Fall Time and Precision
     Test                                                              "-^

(Also may indicate voltage variation and ambient temperature sensitivity)
                                                         *

     A.   Definitions

          Zero Drift - This value is the change in response to zero
          pollutant concentration over  a 24 hour period of continuous
          unadjusted operation.

          Span Drift - This value is the percentage change in response
          to pollutant concentrations of 80% of scale and 20% of scale
          over a 24 hour period  of continuous unadjusted change.

          Lag Time - The time interval  between a change in pollutant
          concentration input and a corresponding change in scale readings.

          Rise Time - The time interval between an increase in pollutant
          concentration input and 95% response to a new concentration
          level.

          Fall Time - The time interval between a decrease in pollutant
          concentration input and 95% response to the new concentration.

          Precision - Precision  is defined as a variation about the mean
          of repeated measurements of the same pollutant concentration
          expressed as one standard deviation about the mean.

     B.   Test Procedure - The monitor  should be set up in such a manner
          that the voltage and temperature may be controlled (or recorded)
          and, if possible, altered experimentally to levels the monitor
          may be expected to encounter.  If the instrument is to be
          housed in a tightly controlled environment, the monitor need
          be tested only in a duplication of that environment.  This
          test procedure need only be performed once if the instrument
          is to be used in a controlled environment; at least three test
          runs must be performed at varying environmental conditions if
          the instrument will be subject to voltage and temperature
          fluctuations at a monitoring  site.  In either case, more
          testing should be done if the instrument responds irregularly.
          During this procedure  no manual adjustments to the electronics,
          gas or reagent flows,  other than those specified by the test,
          or as part of a required periodic maintenance program, is to
          be performed.
               The instrument shall be operated at 115 volts and at
               25°C.
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                                                                      QA 6.2.1.1
                                                                      Revision «5
                                                                      Page 8 of 28
                           1.   Allow sufficient time for instrument warm-up and
                                stabilization.  Adjust the zero baseline to 5 percent
                                of full scale.  Recalibrate if necessary.  (Usually
                                if the span check indicates a span drift in excess
                                of the value listed in Table I.)

                           2.   Arrange to generate test atmospheres as follows:

                      Test Atmosphere          Pollutant Concentration (Percent)

                                               URL » Upper range limits
                           A0                 "           Zero gas
                           A2Q                           20 + 5 of URL
                           A3Q                           30 + 5 of URL
                           ABO                           80 + 5 of URL
                           Ago                          ' 90 + 5 of URL

                           Set chart speed at 2 inches/hr.

                           3.   Measure AQ until a stable reading is obtained.
                                Record reading as Z!Q.  Note the clock time on  the
                                strip chart.

                           4.   Measure &2Q until a stable reading is obtained.
                                Record reading as M^-Q.  Note the clock time on  the
                                strip chart.
7                           5.   Measure Ag« until a stable reading is obtained.
                                Record reading as S^-Q.  Note the clock time on  the
                                strip chart.

                           6.   Sample Ag until reading is less than 15 percent of
                                full scale.  A stable reading is not required.

                           7.   Measure A2Q-  Record stable reading as P^.

                           8.   Sample A3Q.  A stable reading is not required.

                           9.   Measure A2Q-  Record stable reading as P2-

                           10.  Sample AQ.  A stable reading is not required.

                           11.  Measure A2Q.  Recor(* stable reading as P^.

                           12.  Sample A3Q.  A stable reading is not required.

                           13.  Measure A2Q-  Record stable reading as P^.

                           14.  Sample An.  A stable reading is not required.
                            15.  Measure A2Q»   Record  stable  reading  as PS-     -
                            16.  Sample A3Q.   A stable reading is  not required.

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                                                                       Page 9 of 28
 I                        17.  Measure A2g.  Record stable reading as Pg.  Note the
\                               clock time on the strip chart.
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               18.   Measure AQQ.   Record stable reading as Py.
               19.   Sample Agg.   A stable reading is not required.
               20.   Measure Agg.   Record stable reading as Pg.  Set
                    chart speed  at 4 inches/hr.
                                                                      •
               21.   Measure AQ.  Record stable reading as L]_.
               22.   Quickly switch test analyzer to measure Agg.  Mark
                    recorder chart at exact time of switch.
               23.   Measure Agg.   Record stable reading as Pg.
               24.   Sample Agg.   A stable reading is not required.
               25.   Measure AQQ.   Record stable reading as P^g.
               26.   Measure AQ.   Record stable reading as L2>
               27.   Measure Agg.   Record stable reading as PJJ_.
               28.   Sample AQ.   A stable reading is not required.
               29.  Measure Agg.  Record stable reading as P^-  Note
                    the clock time on the strip chart.
               30.  Measure AQ.  Record stable reading as Z-,.  Note the
                    clock time on the strip chart.
               31.  Measure A2g.  Record stable reading as M^.
               32.  Measure Agg.  Record stable reading as S^.
               33.  Zero Drift
                       Zero Drift - zk> - Z^
               Report the Elapsed Testing Time as Measured in Steps
(3)  and (30).
               34.  Span Drift
                    (a) at 20% URL
                         Span Drift - ^a -  Mo  x 100%
                                     ~
                                     where:
                           Report the Elapsed Testing Time as Measured  in  Steps  (4)  and (17).
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                                            (JH O.^.JL.JL
                                            Revision i
                                            Page 10 of  28
     (b)  at 80% URL

          Span Drift
                      S  -  S
                       n     ox 100%
          where:
                           o
                           12
                  s-l   if,',
     Report the Elapsed Testing Time as Measured in Steps
     (5) and (29).

35.  Lag Time

     Determine from the strip  chart, the elapsed time in
     minutes between the mark  made  in  step  22 and  the
     first observable (2 x noise  level) response.

36.  Rise Time

     Calculate 95 percent of reading Pg and determine
     from the recorder chart the  elapsed time between the
     first observable (2 x noise  level) response and a
     response equal to 95% of  Pg.

37.  Fall Time

     Calculate 95 percent of (P10 - L2) and determine the
     elapsed time in minutes between  the first  observable
     decrease in response following PIQ and the response
     equal to 95 percent of (P^Q  -  L2).
38.  Precision

     Calculate precision (?2Q  an<*

     (a)
         P20 ^
                                       as follows:
               -f6    2   ~(<   \
          80
               1 fl2     "  1 /12  \2
               5   £  pJ-6   £P,
                 Li-7  i     \±-7 *•] ^
Obtain a stable zero air reading.  Record.   Introduce a
test atmosphere of 80% of scale.  Allow instrument to run
and record at this level for 24 hours.   At  the end of the
24 hour period, return to zero air and obtain a stable
reading.  Report the ppm value for the first hourC^) and
for the last hour (X2) .  Report span drift  (80%) as X? -
                                                               IQQ

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                                                          Revision <5
                                                          Page 11 of 28
          3.    Day 3

               After obtaining and recording the  zero air reading,
               introduce a 20% of scale test atmosphere.   Allow instrument
               to run and record at this level for 24 hours.  Return to
               zero air and record the stable reading.  Report the ppm
               value for the first hour (Y^) and  for the last hours
               Report span drift (20Z) as Y£ - Yj   ^QQ
          4.   Day 4

               Repeat day 2 procedures, except allow instrument to run
               for 48 to 72 hours.

          5.   Day 6

               Repeat day 4 procedures, except use zero air.

          If the instrument will be operated under conditions of fluctuating
          temperatures and voltages, repeat this test procedure (beginning
          with Day 1) at least two more times, altering ambient temperatures
          and voltage levels to settings the instrument is likely to
          encounter in the field.

IV.  Interference Test

     A.   Definition - Interference is the positive or negative effect
          of a substance, other than the pollutant being measured, as
          reflected in instrument response.

     B.   Test Procedure - The test procedure will vary depending on the
          instrument and its potential interferences.  The procedures to
          be used will be written by the QA Coordinator (in conjunction
          with the testing group) prior to the beginning of the testing
          phase.

V.   Flow Rate Measuring Device - Factors to be taken into consideration
are the accuracy of the device, ease of calibration (either in or out of
the sampling line), ease of adjustment and flow rate drift.  Data from
this test should be recorded as in Figure 3.

     A. x  Test Procedure -

          1.   Calibrate the flow rate controller, as specified in the
          instrument operation's manual, with a transfer standard of
          known high accuracy (such as a wet test meter, soap bubble
          meter or mass flow meter).  Thereafter, run a daily flow rate
          check of one or more points to check the flow rate controller's
          stability.  Report the maximum 7. deviation in the flow rate
          calibration.

          2.   Record the flow rates each day, as indicated on the
          instrument's flow rate measuring devices for each parameter of

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\
                                                            QA 6.2.1.1
                                                            Revision i
                                                            Page 12 of 18

          interest (H2 flows, sample flows, etc.).  Report the maximum %
          variability in the flow rate readings for each parameter
          measured.

     For further details regarding any of the above tests, please refer
     to the February 18, 1975 Federal Register - Ambient Air Monitoring
     Reference and Equivalent Methods Fart II.

VI.  Calibration Drift

When all testing is complete, run a multipoint calibration of the
analyzer.  DO NOT ADJUST ZERO OR SPAN SETTINGS ON THE INSTRUMENT.
Compare with the initial calibration as follows:

     A.   Determine the slope and intercept for each calibration; X »
          ppm, Y = instrument reading.

     B.   Using the slope and intercept for each calibration determine
          the ppm values at each instrument reading from 10 to 100% in
          units of 10 (see Figure 5).

     C..   Determine the percent differences for each ppm value obtained
          in B.  Assume the initial calibration value is the "true
          value."                                        _

     D.   Report the average percent difference as:


                         i
               I Diff - 1=1  di
          'Note that the absolute values of the percent differences are
          used.

     E.   Report the maximum percent deviation observed in the region in
          which ambient concentrations will fall.  Report this data on
          Figures 4 and 5.  Instructions for completing Figure 4 precede
          the figure.

A report must be prepared which includes all the original data, strip
charts, calculations and calibrations.  In addition, the calculated
data - span drifts, calibration drifts, etc., should be organized into
tables for purposes of comparison.  The following areas determined in
the "Specification and User Review" and in the "Instrument Testing"
should be included in this report.

          1.   Vendor Cooperation

               a.   willingness to comply with terms of DNR prepurchase
                    and purchase specifications.

                                                        
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                    supplier) purchase of parts.  Specify parts available
                    only from vendor.
               d.   instrument delivery time for all ordered monitors


               e.   condition of the monitor when received for "instrument
                    testing"


               f.   warranty terms


          2.   Required support equipment - What is needed in terms of
               supporting electronics, gas cylinders, etc. and availability
               of such.  Detail which items we already own and which
               would have to be purchased.


          3.   Annual operation's cost - Approximate cost of parts,
               reagents, electronics, gas cylinders and manpower support.


          4.   Operations Manual


               a.   ease of comprehension


               b.   completeness (including wiring blue prints)


          5.   Ease of Access for:


               a.   instrument repair


               b.   routine maintenance


               c.   hook up, either free standing or rack mounted


               d.   routine calibration


               e.   of knobs, switches, and dials


          6.   Conformity to Existing Instrumentation Systems


               a.   manifold


               b.   data acquisition system


               c.   rack mounting


          7.   Aesthetic Appeal


Consideration of where and how instrument is to be used should be kept
in mind in making a subjective evaluation.  Where problems are specific
to a certain use of the instrument (ex. if used in the vans it's a
problem) specify this in describing the problem.


The report should be completed within 30 days of the end of the project.
It should then be circulated for comment and recommendations to key
persons within the monitoring program who are knowledgeable in this
area.  The report  should also be forwarded to the Bureau for filing.  A

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                                                          QA 6.2.1.1              I
                                                          Revision i              ™
                                                          Page 14 of 28
final decision as to instrument purchase should be made within two                •
weeks.  The  decision   will be made at a conference (phone or personal)
with representatives of each monitoring group and the QA Coordinator.             •
NOTE;
When a decision on instrument purchase must be made rapidly, a shortened          I
version of this report - just containing the charts and tables from the           •
evaluations should be circulated for comment immediately.  The remainder
of the report is still to be written and added to the tables at a later           •
date.                   .                                                          I
A sample copy of a procurement report is available from the Quality
Assurance Coordinator.                                                            •
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 B                                                                    Page 15 of 28
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                                        FIGURE 1
                                 AMBIENT AIR  ANALYZERS

                                     USER FACT SHEET
           INSTRUMENT MANUFACTURER AND MODEL NUMBER
           COMPANY NAME 	  DATE
           COMPANY CONTACT 	  PHONE NUMBER


           DNR CONTACT 	





            1.  GENERAL INFORMATION


                a.   How many analyzers do you own?
I              b.   How long have you operated the analyzers?



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            2.  MECHANICAL DEPENDABILITY

|              a.   In the time since you have owned the instruments,  how many
                     mechanical breakdowns, on average,  have  you experienced?


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                b.   Do any specific parts give more breakdown  problems than
• .                  others?  If so, which ones?




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QA 6.2.1.1             I
Revision «S             M

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                                                           Revision
                                                           Page 16 of 28
3.  ELECTRONIC DEPENDABILITY
         In the time since you have owned the instruments,  how many               •
         electronic breakdowns, on average, have you experienced?
4.  CHEMICAL DEPENDABILITY
    a.   What is the average zero and span drift you see on the
         instrument - in ppm/x days or in Z chart/x days?
    b.   How frequently do you perform zero/span checks?
                                                                                  I
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    b.   Do any specific parts give more breakdown problems than
         others?  If so, which ones?
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    c.   How frequently do you have to perform a multipoint cali-
         bration on the analyzer?                                                 I

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                  e.   What is the response time on the instrument - in minutes or
                       seconds - to reach 95Z of scale from the baseline?
              5.  EASE OF WORKING WITH THE INSTRUMENT
   *     •                                                               QA 6.2.1.1
                                                                        Revision  b
   •               .                                                     Page  17 of  28


   •             d.   How long does it take to perform the multipoint calibration?




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  *              a.   Are the control switches and knobs easily accessible to
                      the operator?





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                 b.   How easy is it to

                      1.   replace boards?



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                      3.   replace filters or other parts?





                      Be specific (example:  flow controllers cannot be reached
                      without dismantling...etc.).
I)

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                                                           QA 6.2.1.1
                                                           Revision ?5
                                                           Page  18  of 28
6.  VENDOR RESPONSIVENESS
    b.   What is the quality of the repair work performed by the
         vendor or manufacturer?  Be specific.
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         How sophisticated mist the user be to operate the instrument?
         Can an engineer operate it?  An electronics technician?   A   ^^^        H
         chemist?                                                                  I
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         What is the turnaround time on vendor repair of instruments?              •
         Be specific - in days, weeks,  etc.                                        I
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         How long does it take to get a. vendor or manufacturer repair             _
         person to the field?                                                     •
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                                                                       QA 6.2.1.1
                                                                       Revision j5

                                                                       Page 19 of 28
 \               d.   Are vendor representatives knowledgeable about the instrument,
 Jm                  Its operation and potential problems?




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 •         7.  COST 07 OPERATION

I                a.   What parts, chemicals or other equipment must be  replaced
                     frequently?



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                b.   How expensive are replacement parts?   Be specific.





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 •              c.   Row much time must be spent by repair people, operators,
                     electronics people, chemists, etc., to keep the instruments
      ""              operational?





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                                                       rage zu or zo
8.  INSTRUMENT DOWN TIME
     What percent data capture do you average, or how many hours/unit
     time (day, month, etc.) are the instruments inoperable?
9.  INTERFERENCES
                                                                             »
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b.   What is the major reason for your instrument down time?                 '

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a.   Are there any common interferences (gases in the ambient
   .  air, at the site; temperature variations, etc.) which affect
     the response of the instrument?  If yes, what are they?                  I
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b.   Bow badly is the instrument affected by the interferents?
     Be specific.
                                                                              I

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                                                                           I- ----
                                                                      Revision i
                                                                      Page 21 of 28


M        10-  GENERAL INFORMATION
;                                                                                 ^v
I               a.   Have you used any other manufacturer's analyzers?  If yes,
                    which ones?



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               b.   If you had a choice, would you purchase this analyzer again?
 •                  Why?




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               c.   Any other comments not covered above.



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Revision i
Page 22 of 28
. ' FIGURE 2
, AMBIENT AIR ANALYZERS
} INSTRUMENT PERFORMANCE DATA SHEET
t
Instrument Manufacturer
and Model #
Instrument Serial #
EPA PERFORMANCE SPECIFICATIONS
Range

Noise
Lower Detectable Limit
Interferent Equivalent
24 hrs.
Zero Drift
Span Drift
-"
Lag Time
Rise Time
. Fall Time
" Precision

5,'
Date
Pollutant
. PERFORMANCE SPECIFICATION RESULTS
(Minimum)
(Maximum)
(So)
(SHV)
(B.-B,)
(2x noise)
(Interferents(s))
Result
24 hrs 48 hrs 72 hrs
24 hrs 48 hrs 72 hrs
20%URL
80HJRL


>
._ 	 _ PO«


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    Instrument Manufacturer
    and Model Number   	
    Calibrator S/N#
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   Recorder Zero Setting
• Zero Setting 	
   Span Setting 	
                                                                      Revision tf
                                                                      Page 23 of 28
                                     .  FIGURE 3

                         PERFORMANCE SPAN AND FLOW RATE CHECKS
                               Analyzer S/Ntf
                               Last Generator Calibration
Date







Rotameter
Setting







Flow
cc/min







Calibration Output







Analyzer Response

.


\


Sample
Flow Rate







*Z Diff .







    *Z Diff.
Analyzer Response - Calibration Output A 100Z
          Calibration Output           /
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    Auxiliary Gas Flow Rate
    (Specify gas)
   Remarks:
                                                     Method(s) of Analyzer Data Retrieval
                                                        Strip Chart 	
                                                        Data Averages _____
                                                        Data Logger 	

                                                     How was sample flow rate determined?

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                         CALIBRATION FORM
                                                            revision 0              •
                                                            Page  24  of 28            |



                                                                                    I



1.   Instrument manufacturer and model number - The manufacturer's
     name, the model number of the analyzer.                                         _

2.   Instrument number - The manufacturer's serial number affixed to                ™
     the analyzer.                                                     <

3.   Initial calibration date - Date of the first calibration of  the                |
     analyzer.

     By - Name of person performing the calibration.                                •

4.   Final calibration date - The date of the final calibration of the
     analyzer.                                                                      •

     By - The last name or initials of the person performing the
     calibration.                                                                   tm

5.   Generator number - The DNR serial number for the generator used to
     calibrate the analyzer.

6.   Date of last generator calibration - The date the generator  was                I
     calibrated.

7.   Remarks - Any comments on instrument performance that would  affect             •
     the interpretation of the calibration data.

8.   This information is completed for all analyzers.                               I

     a;   Sample flow rate - The sample air rotameter setting.

     b.   Auxiliary gas flow rate - Flow rate of any gases used by                  •
          the analyzer (example;  air, hydrogen, ethylene).

          Zero setting - If the instrument is so equipped, this is                  •
          the reading on the zero control setting.


                                                                                    I
          Span setting - The reading from the span setting.                         _

                                                                                    •
     d.   Zero offset - The Z chart reading when zero volts is applied
          to the recorder.
9.   Number 8 is completed twice for each instrument calibration.   The
     values for each parameter are entered into the INITIAL column when
     the instrument is first calibrated,  and each parameter is then
     recorded in the FINAL column when the final calibration is com-
     pie ted.
                                                                                    I

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• ' Revision i
Page 25 of 28

There are eight columns on the bottom half of the form. These are
completed for both INITIAL and FINAL calibrations.
1. Generator setting - In this column place first the number on the
lamp position switch if ozone is used. After it, place the rotameter
setting.
2. Generator concentration ppm - The output from the generator for the
rotameter setting and position switch setting used.
3. Initial chart reading. Z FS - This column lists the Z chart reading
for the pollutant value in column 2 when the Instrument has the
span setting found in the INITIAL column.
4. Initial instrument reading ppm - This is the instrument reading
found on the instrument panel when a given quantity of pollutant
is passed to it.
5. Final chart reading Z FS - This column lists the Z chart reading
for the pollutant value in column 2 when the instrument has the
span setting found in the FINAL column.
6. Final instrument reading ppm - This is the instrument reading for
a given quantity of pollutant at the FINAL calibration.
7. Percent - This is the percent deviation of the instrument from the
true pollutant concentration. It is calculated twice. The top
half of the column gives the initial percent. This is defined as:
Generator ppm - Initial reading x 100
Generator ppm
or
Column 4 - Column 2 x 100
Column 2

The bottom half of the column lists the final percent. This is
defined as:
Generator ppm - Final reading x 100
Generator ppm
or
Column 6 - Column 2 x 100
Column 2 . .

•

. -.; 	 .'•"""''."-. "'•"-•--• - - • - - t- -

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INSTRUMENT MANUFACTURER
AND MODEL NUMBER
FIGURE 4
CALIBRATION FORM

INSTRUMENT
INITIAL CALIBRATION DATE
BY
Revision i
Page 26 of 28
NUMBER

FINAL CALIBRATION DATE BY
GENERATOR NUMBER

REMARKS:
DATE OF LAST GENERATOR CALIBRATION


SAMPLE FLOW RATE

INITIAL FINAL
CALIB. CALIB.
AUXILIARY GAS FLOW RATE

(SPECIFY GAS)
ZERO SETTING
ZERO OFFSET
(Z CHART)
SPAN SETTING
OTHER (SPECIFY)
GENERATOR SETTING
POSITION
SWITCH
(
ROTO /
SET. sS
./FLOW
S (CC/MIN)
L)








~"
GENERATOR
POLLUTANT
PPM
(2)
-








INITIAL
CHART
READING
(Z FS)
(3)









INITIAL
INSTRU.
READING
ppb
(4)









FINAL
CHART
READING
(Z FS)
(5)









FINAL
INSTRU.
READING
ppb
(6)










-



An /
INITIAL/
/ AZ
/ FINAL









COMMENTS









1
1
1
1
1
1
1
1
1
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                                                                      tJA 0.2.1.1
                                                                      Revision <5
                                                                      Page 27 of 28
    4 Z INITIAL  -  Col. A-Col. 2
 •                      Col. 2

    4 Z FINAL  -  Col. 6-Col. 2
 •                    Col. 2
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                                                                  QA 6.2.1.1       .        •
                                                                  Revision <5               •
                                                                  Page 28 of 28
                                      FIGURE 5
                               CALIBRATION DRIFT TEST


INITIAL SLOPE   	    FINAL SLOPE
INITIAL INTERCEPT 	    FINAL INTERCEPT
DATE OF CALIBRATION	.         DATE OF CALIBRATION
AVG. Z DIFFERENCE	•
                       INITIAL                FINAL                    I
Z CHART                 VALUE                 VALUE                DIFFERENCE
 10
 20
 30
 50
 60
 70
 80
 90
100
Z DIFF. - FINAL VALUE - INITIAL VALUE x 100
                 INITIAL VALUE
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                                APPENDIX   6

                   EPA OFFICIAL ANALYTICAL METHODOLOGY



                     PRIOROTY POLLUTANT MEASUREMENTS
     Recommended analytical  methods for priority  pollutants  are  described
in "Sampling and Analysis Procedures for Screening  of  Industrial  Effluents
for Priority Pollutants"  available from the  Environmental Monitoring and
Support Laboratory, EPA,  Cincinnati, Ohio 45268.

     These guidelines for sampling and  analysis of  industrial wastes have
been prepared by the staff of the Environmental Monitoring and Support
Laboratory - Cincinnati,  at  the request of the Effluent Guidelines Division,
Office of Water and Hazardous Wastes, and with the  cooperation of the
Environmental Research Laboratory, Athens, Georgia.  The procedures represent
the current state of the  art, but improvements are  anticipated as more
experience with a wide variety of industrial  wastes  is obtained.  Users of
these methods are encouraged to identify problems encountered and to assist
in updating the test procedures by contacting the Environmental  Monitoring
and Support Laboratory, EPA, Cincinnati, Ohio 45268.  These  methods were
first made available in March 1977 and  were  revised-in April 1977.

-------
                                                                                I

                                                                                I
                                APPENDIX   7
                   EPA OFFICIAL  ANALYTICAL METHODOLOGY                           I

                       HAZARDOUS WASTE  MEASUREMENTS                              |
                                                                               1
     Samples will  be collected  in  containers  prepared by the CRL and
shipped to the National  Field  Investigation Center - Denver, for                •
extraction.  The extract will  be returned to  the CRL lab for analysis.          |

     NEIC  expects  to be  ready  to start  processing samples in about              _
three months.  A safety  manual  for handling these materials which will          I
presumably contain information  on  containers  and shipping is also being         •
prepared.

     The collection of samples, preparation of  containers, etc., is             I
to be coordinated  through the  Director  of the CRL.  Existing Agency
test procedures are to be used  until  test procedures specifically for           •
the hazardous waste program have been finalized by the Agency.                  I
                                                                               I

                                                                               I

                                                                               I

                                                                               I

                                                                               I

                                                                               I

                                                                               I

                                                                               I

                                                                               I

                                                                               I

-------
1
1




1
1
PARAMETER
1 Parti cul ate Filters

| Sulfur Dioxide
(Pararosanili ne Method)


1 Nitrogen Oxides
(Sodium-Arsenite Method)

• Fluoride




1
1
1
1
1
1
1


APPENDIX 8

SAMPLE COLLECTION, PRESERVATION, AMD
HOLDING TIMES
AMBIENT AIR SAMPLES
REC OMMENDED
HOLDING TIME PRESERVATION METHOD
Indefinite Store in controlled
atmosphere of <50%
relative humidity

30 days, if Store at <4°C after
properly stored collection, during
transport, and
before analysis
6 weeks Samples are stable
for 6 weeks at room
temperature
None Collect and store
in plastic
containers










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                                        APPENDIX 14
                                                                      Page 1  of 3
                 SAMPLE COLLECTION CONTAINERS, PRESERVATIVES,  AND HOLDING
                TIMES FOR SAMPLES COLLECTED IN THE 1412 MONITORING PROGRAM
                                        CHEMISTRY1
I
PARAMETER
PRESERVATIVE2
CONTAINER3
MAXIMUM
HOLDING
TIME4
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Arsenic
Bari urn
Cadmium
Chromium
Lead
Mercury

Nitrate
Selenium
Silver
Fluoride
Chlorinated
  hydrocarbon

Chlorophenoxys
Cone. HN03 to pH<2
Cone. HN03 to pH<2
Cone. HNOs to pH<2
Cone. HNOs to pH<2
Cone. HN03 to pH<2
Cone. HN03 to pH<2
Cone. H2$04 to pH<2
Cone. HN03 to pH<2
Cone. HN03 to pH<2
None
Refrigerate at 4°C as
soon as possible after
collection
Refrigerate at 4°C as
soon as possible after
collection
  P or G
  P or G
  P or G
  P or G
  P or G
  G
P
  P or G
  P or G
  P or G
P or G
G with foil or
Teflon lined cap

G with foil or
Teflon lined cap
  6 months
  6 months
  6 months
  6 months
  6 months
  38 days
14 days
  14 days
  6 months
  6 months
1 month
14 days5

7 days^
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1 - If a laboratory has no control  over these factors,  the  laboratory  director must
    reject any samples not meeting  these criteria and so  notify  the  authority
    requesting the analyses.
2 - If HNOs cannot be used because  of shipping restrictions,  samples may  be  initially
    preserved by icing and immediately shipping it to the laboratory.   Upon  receipt  in
    the laboratory, the sample must be acidified with concHN03 to  pH<2.   At  time of
    analysis, sample container should be thoroughly rinsed  with  1:1  HNOs; washings
    should be added to sample.
3 - P = Plastic, hard or solf; G =  Glass, hard or soft.
4 - In all cases, samples should be analyzed as soon after  collection  as  possible.
5 - Well  stoppered and refrigerated extracts can be held  up to 30  days.

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PARAMETER


Gross alpha
Gross beta
Stronti um-89

Stronti um-90
Radi um-226
Radium- 228
Cesium-134
•Iodine-131
Tri ti um
Urani um

Photon emitters

1 - "Federal Register"
2 - It is recommended
collection unless
sample must be shi
sample (in its ori
5 days. A minimum
3 - P = Plastic, hard
4 - If KH is used to
APPENDIX 14 (Continued)
RADIX HEMISTRY1
PRESERVATIVE2


Cone. H:i or HN03 to pH<24
Cone. H31 or HN03 to pH<24
Cone. K;i or HN03 to pH<2

Cone. KM or HN03 to pH<2
Cone. fCl or HNC^ to pH<2
Cone. hCl or HN03 to pH<2
Cone. H:i to pH<2
None
None
Cone. H31 or HN03 to pH<2

Cone. KT1 or HMOs to pH<2

, Volume 41, No. 133, July 9, 1976.
that the preservative be added to the sample
suspended solids activity i s to be measured,
Page 2 of 3

CONTAINER3


P or G
P or G
P or G

P or G
P or G
P or G
P or G
P or G
G
P or G

P or G


at the time of
However, if the
pped to a laboratory or storage area, acidification of the
ginal container) may be delayed for a period
of 16 hours must elapse between acidificati
or soft; G = Glass, hard or soft.
acidity samples which are to be analyzed for
not to exceed
on and analysis.

gross alpha or
gross beta activities, the acid salts must be converted to nitrate salts
before transfer of




the samples to planchets.









1
1





1



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1




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                                                                           Page 3 of 3
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APPENDIX 14 (Continued)

      MICROBIOLOGY
 DRINKING WATER SAMPLES
 I                Sample bottles must  be of  at  least  120ml  capacity, sterile plastic
             or hard glass,  wide mouthed with  stopper or  plastic  screw cap and capable
 |           of being sterilized repeatedly.   10mg/l  sodium thiosulfate is added to
 _           the sample during preparation.  Sample volume  must be  at least 100ml.
 ™           Samples must be analyzed  within 30 hours after collection.   If a State
 •           principal  laboratory is  required  by State regulations  to examine samples
             after 30 hours  and up to  48 hours, the laboratory must indicate that the
 •           data may be invalid because of  excessive delay before  sample analysis.
             Samples arriving 48 hours shall be refused without exception and a new
 M           sample requested.

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               APPENDIX  15
                  UNITED STATES ENVIRONMENTAL PROTECTION

  'vTt'   MAR G   1378
  ;CT-.   Approved Alternative Analytical
       Methods - Nationwide Use

  !OM:   victor J. Kimm, Deputy Assistant
       Administrator for Drinking Water (WH-550)

  T0:   All Regional Admjjiistrators

       Listed below are additional alternative analytical methods for
       nationwide use which I have approved for the National Interim
       Primary Drinking Water Regulations.  As stated in my March 10,
       1977 menorandum on this subject, publication of new alternate
       analytical methods will eventually follow in the Federal Register.

       Specific questions regarding the details of these procedures
       should be directed to the Director, Environmental Monitoring
       and Support Laboratory, Cincinnati.
            Measurement
       Organics  (Pesticides)
       Fluoride
       Fluoride
                Method

"Standard Methods for the Examination of
Water and Wastewater,11 14th ed., 1975.
Organochlorine Pesticides, part 509A,
pp. 555-564, Chlorinated Phenoxy Acid
Herbicides, part 509B, pp. 565-569.

Modified Automated Alizarin Blue. Ref:

"Fluoride in Water and Wastewater,"
Industrial Method S129-71W, December 1972,
Technicon Industrial Systems
Tarrytown, NY  10591

Automated Electrode Method, Ref:

"Fluoride in Water and Wastewater"
Industrial Method £380-75WE,
February 2, 1976, Technicon Industrial
Systems, Tarrytown, NY  10591
     cc:  Water/
          S & A
          A & H M
A Fr.,,, 1370 I. IR,.v. 3 76)
                                                                   MAR 1 5 1978

                                                                   EPA REGION 5
                                                                  OFFICE OF RCGIONAl

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       DM


     SUBJE
                   UNITED
   a,.. SEP   11977
                                                           AGEHCY
    ~T:  Approved Alternative Analytical
       CMthods -Nationwide Use
                    J. Kimm, Deputy "Assistant  •
         //Administrator for Water Supply (WH-550)
         TO:  All Regional Administrators
                                                     jYCuOrDirty.oi'Ofi
             This memorandum replaces my earlier memo of May 10 on this subject,
             since questions at the regional/State level concerning its implementation
             have been raised. In addition,  some points need further clarification
             and comment prior to official publication of the approved alternate
             analytical methods in the Federal Register.

             In order to expedite the publication of these needed alternate analytical
             methods and to correct and clarify inaccuracies and other  possible
             ambiguities which may have occurred as the result of collective actions
             the approved methods for nationwide use are summarized below; hence,
             iny May 10 memo should be disregarded.
             Measurement
             Arsenic
             Arsenic
             Barium
             Cadmium
             Chromium
             Fluoride
                                                 Method
                               Flameless Atomic Absorption, Graphite
                               Furnace Technique.

                               Silver Diethyldithiocarbamate Method, Ref:
                               "Methods for Chemical Analysis of Water and
                               Wastes, "pp. 9-10, EPA Office of Technology
                               Transfer,  (1974).

                               Flameless Atomic Absorption, Graphite
                               Furnace Technique.

                               Flameless Atomic Absorption, Graphite
                               Furnace Technique.

                               Flameless Atomic Absorption, Graphite Furnace
                               Technique.

                               Automated Alizarin Fluoride Blue, Ref: "Stan-
                               dard Methods for the Examination of Water
                               and Wastewaier," 14, pp. 614-616, (1375)
CPA Fcrm 1310-t fRc». 3-761

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Fluoride
Lead
Mercury
Nitrate
Nitrate
Organics
Selenium
Selenium
Silver
                                       APPENDIX 15  (Continued)
Zirconium-Eriochrome Cyanine R. Ref: "Methods
for Collection and Analysis of Water Samples for
Dissolved Minerals and Gases," USGS, Book 5,
Chapter A 1,  pp. 90-93.

Flameless Atomic  Absorption, Graphite
Furnace Technique.

Automated Cold Vapor Technique, Ref: "Methods
for Chemical Analysis of Water and Wastes,"
pp. 127-133, EPA Office of Technology Trans-
fer, (1974).

Automated Hydrazine Reduction,  Ref:  "Methods
for Chemical Analysis of Water and Wastes,"
pp. 185-194, NERC Analytical Quality Control
Laboratory, (1971).
Automated Cadmium Reduction, Ref: "Methods for
Chemical Analysis of Water and Wastes, " pp. 207-
212, EPA Office of Technology Transfer, (1974).    I

Gas Chromatographic, Ref: "Methods for Analysis
Organic Substances in Water," USGS, Boo1- 5,v
Chapter A 3,  pp. 24-39.
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Hydride generation - atomic absorption
spectrophotometry,  USGS. Method, 1-1667-77,
(1976).

Flameless Atomic Absorption, Graphite Furnace
Technique, Ref: Atomic Absorption Newsletter,
14, No. 5, pp. 109-116, (1975).

Flameless Atomic Absorption, Graphite Furnace
Technique.
Once it is published, you will be provided with copies of the FR
notification by my office. In the interim, these methods may be
considered as approved alternative analytical methods to meet the
monitoring requirements of the SDWA.  Additional information on
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                                                      APPENDIX 15 (Continued
the flameless atomic absorption graphite furnace technique is
available from the Director of the Environmental Monitoring
and Support Laboratory in Cincinnati until the 1974 EPA
manual is updated.
1
 The various furnace devices are considered to be atomic absorption
techniques.  Methods of standard addition are to be followed as noted
on p. 78 of "Methods for Chemical Analysis of Water and Wastes, "
EPA Office of Technology Transfer,  (1974).

2
  Copies available from:  Water Quality Branch, National Center
U.S. Geological Survey,  112201 Sunrise Valley Drive, Reston,
Virginia 22092.

3
 Oily the six pesticides named in the Interim Primary Drinking
Water Regulations are included: Endrin,  Lindane, Methoxychlor,
Toxaphene; 2,4-D; and 2,4;5-TP (Silvex).  Federal Register,
Vol. 40, No. 248, pp. 59570-59571, Dec. 24, 1975.

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"                     •                   APPENDIX 16

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                         PERFORMANCE TESTS FOR THE EVALUATION

                                   OF COMPUTERIZED

                         GAS CHROMATOGRAPHY/MASS SPECTROMETRY

                              EQUIPMENT AND LABORATORIES
                                           by
                                    William L.  Budde           	
          I— -  •• •                   •     and
                                 James W.  Eichelberger



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1                    Environmental Monitoring and Support Laboratory
                           Office of Research and Development
                          U.S.  Environmental Protection Agency
 •                              Cincinnati, Ohio  45268



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         -               ,                                                      •       I
  ...... ____         ._               ...... _______________          I

                                                                                     I
 ;""   "" ......                DISCLAIMER                   "~ ..... ~"    "
    This report has been reviewed by the Environmental Monitoring and                •
Support Laboratory, U.S. Environmental Protection Agency, and approved for
publication.  Mention of trade names or commercial products does not                 •
constitute  endorsement or recommendation for use.                                    I
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                                   FOREWORD  -	


    Environmental measurements are required to determine the quality of
ambient waters and the character of waste effluents.  The Environmental
Monitoring and Support Laboratory - Cincinnati, conducts research to:

    + Develop and evaluate methods to measure the presence and concentra-
      tion of physical, chemical, and radiological pollutants in water,
      wastewater, bottom sediments, and solid waste.

    •*• Investigate methods for the concentration, recovery, and identifica-
   — tion of viruses, bacteria and other microbiological organisms in
      water; and, to determine the responses of aquatic organisms to water
      quality.

    +• Develop and operate an Agency-wide quality assurance program  to  assure
      standardization and quality control of systems for monitoring water
      and wastewater.

    + Develop and operate a computerized system for instrument automation
      leading to improved data collection, analysis, and quality control.

    This report was developed by the Advanced  Instrumentation Section  of  the
Environmental Monitoring and Support Laboratory.  It describes a series of
general purpose tests to evaluate the performance of computerized gas
chromatography-mass spectrometry (6C/MS) systems.  Some of the tests go
beyond equipment performance and may be used to evaluate the performance  of
laboratories using GC/MS for organics analysis.  The report will be useful
to the many Federal, State, local government,  and private  laboratories that
are planning to employ this powerful analytical tool.
                                     Dwight S. Ballinger
                                     Director
                                     Environmental Monitoring  and Support
                                     Laboratory - Cincinnati
                                    111

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                                   ABSTRACT
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    A series of ten general purpose tests are described which are used to            |
evaluate the performance of computerized gas chromatography-mass
spectrometry systems.  Evaluation criteria are given with each performance           •
test.  Some of the tests go beyond equipment performance, and may be used to         •
evaluate the performance of laboratories using 6S/MS for organics analysis.
                                      tv
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                                   CONTEHTS


Foreword	i 1 i
Abstract	iv
Figures	vi
Tables	v1
Acknow 1 edgment	 vi 1

    1.  Introduction	1

    2.  Summary of Tests	.3

    3.  Experimental Procedures	5

         Test I    Spectrum Validation	5
         Test II   System Stability	8
         Test III  Instrument Detection Limit	8
         Test IV   Saturation Recovery	11
         Test V    Precision	12
         Test VI   Library Search	36
         Test VII  Quantitative Analysis with Liquid-Liquid Extraction	17
         Test VIII Quantitative Analysis with Inert Gas Purge and Trap	19
         Test IX   Qualitative Analysis with Real Samples	27
         Test X    Solid Probe Inlet System	30

    4.   References	32

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                                                                                       I

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                                                                                       I

                                   FIGURES .                                            I
Number                                                  •               Page            •
  1      Control chart for nitrobenzene In clean water	  21
         Control chart for pyrene 1n clean water	  22           I
2
                                    TABLES                                            |

Number                    _            _ _ .       	    _ _.      Page

  1      Suggested GC Columns and Conditions	   7           |

  2      Decafluorotrlphenylphosphine Key Ions and Ion Abundance	   7           _
         Criteria                                                                     |

  3      Ions Over 3* Relative Abundance Observed in the 70 ev Mass
         Spectrum of DFTPP	  10           •

  4      Common Background Ions in GC/MS Systems	  11        »

  5      Precision Statistics for Ten Priority Pollutants Plus                        |
         Octadecane	  13

  6      Precision Statistics Using an Internal Standard	  15           I

  7      p_-8romofluorofaenzene Key Ions and Ion Abundance Criteria	  16

  8      Precision and Accuracy Data for Liquid-Liquid Extraction                    I
         with GC/MS and an External Standard	  20


  9      Method Efficiencies for Some Priority Pollutants Plus
         p_-Bromofluorobenzene	  25

 10      Precision and Accuracy Data for the Purge and Trap Analysis                •
         with GC/MS and an External Standard	  26

 11      Precision and Accuracy Data for the Purge and Trap Analysis                I
         with GC/MS and the  Internal Standard p_-Bromof luorobenzene	  28
 12      Precision  and Accuracy Data for the Purge  and Trap  Analysis
         with GC/MS and  the  Internal Standard Dibromochloromethane	  29

                                     vi
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^x._

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                                ACKNOWLEDGMENT
    The authors wish to acknowledge the careful and competent technical
assistance of William Middleton, Jr., who has performed all of the GC/MS
tests described in this report at least once, and several of them hundreds
of times.

    A number of Environmental Protection Agency personnel reviewed the first
draft of this report, and many provided written comments which substantially
assisted the authors in the preparation of this document.  Our deep
appreciation is due to all of the following:
William Andrade
Region 1
Surveillance and Analysis Division
Lexington, MA  02173

Thomas A. Beliar
Environmental Monitoring and
Support Laboratory
Cincinnati, OH  45268

Robert L. Booth, Deputy Director
Environmental Monitoring and
Support Laboratory
Cincinnati, OH  45268

Aubry E. Dupuy, Jr.
Pesticides Monitoring Laboratory
Bay Saint Louis, MS  39520
Robert D. Kleopfer
Region 7
Surveillance and Analysis Division
Kansas City, KS  66115

John Logsdon
National Enforcement
Investigation Center
Denver, CO  80225
Dwight G. Ballinger, Director
Environmental Monitoring and
Support Laboratory
Cincinnati, OH  45268

Joseph N. Blazevich
Region 10
Surveillance and Analysis Division
Manchester, WA  98353

Herbert J. Brass
Division of Technical Support
Cincinnati, OH  45268
Denis Foerst
Environmental Monitoring and
Support Laboratory
Cincinnati, OH  45268

John Kopp
Environmental Monitoring and
Support Laboratory
Cincinnati, OH  45268

E. William Loy, Jr.
Region 4
Surveillance and Analysis  Division
Athens, GA 30601
                                     vii

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John M. McGuire
Environmental Research Laboratory
Athens, GA  30601

Aaron A. Rosen
Cincinnati Water Works
Cincinnati, OH  45228
0. C. Shew
R. S. Kerr Environmental
Research Laboratory
Ada, OK  74820
                   *

Alan Stevens
Municipal Environmental
Research Laboratory
Cincinnati, OH  45268
Curt Norwood
Environmental Research Laboratory
Narragansett, RI  02882

Dennis R. Seeger
Municipal Environmental
Research Laboratory
Cincinnati, OH  45268

Clois Slocum
Municipal Environmental Research
Laboratory
Cincinnati, OH  45268

Emilio Sturino
Region 5
Surveillance and Analysis Division
Chicago, IL  60606
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                                  SECTION 1

                                 INTRODUCTION


    This report gives a series of performance tests to evaluate computerized
gas chromatography - mass spectrometry (GC/MS) systems.  These tests were
designed for general use, and are applicable to all types of GC/MS systems.
All of the tests use the continuous, repetitive measurement of spectra
method of data acquisition, and no selected ion monitoring tests are
included.  Except for the spectrum validation test (Test I), these
performance tests are not intended for routine application in a quality
assurance program.  Test I is a required daily quality control test for
GC/MS systems in routine use for measurements of organic compounds in
environmental samples.  The other performance tests are intended for use in
the evaluation of new GC/MS systems before purchase, or after the completion
of the manufacturer's installation. These tests are also useful to evaluate
GC/MS performance after a long period of downtime for extensive maintenance
or repair, after a long period of equipment neglect or non-use, or as
gene'ral training experiments for GC/MS operators.  Several of the tests go
beyond equipment performance and may be used to evaluate the performance of
laboratories using GC/MS for organics analysis.

    The performance tests described in this report are more rigorous and
extensive than the typical manufacturer's installation tests.   Indeed, this
was intended, and the emphasis of the tests is on an evaluation of the total
operating system in a rigorous way using experiments that closely resemble
real, day-to-day operating situations.  The performance tests should be
conducted in the order given, but several are optional or depend on  the
availability of certain accessories, e.g., the solid probe inlet test.

    All the tests described in this report require an operator, and  some
depend heavily on the skills of laboratory personnel.  Therefore, the
results of some tests may be limited by the skills available  in the
laboratory.  An experienced, two-person team consisting of a professional
scientist and a technician will require approximately three weeks to
complete the equipment tests assuming there are no major hardware or
software problems.  Inexperienced teams or individuals may require anywhere
from six weeks to one year to complete all the tests, especially if  major
hardware or software problems develop.  In these tests, the operator and
other laboratory personnel are a crucial part of the total operating system.

    The examples given in this report reference packed column gas chromatog-
raphy, but the tests described are equally applicable to open tubular  GC/MS


                                      1

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systems.  With open tubular  (capillary) systems some minor  adjustments  in             •
operating conditions may be  necessary.                                                |

    For all the tests  1t Is  assumed that the manufacturer has provided                •
acceptable documentation of  users instructions for the operation and                  |
maintenance of the GC/MS system.  At the very minimum this  must  include
clearly written descriptions of all operating and test functions, clear              _
descriptions of all commands used in the operation of the data system,                •
examples of all commands, and intelligible documentation of error messages.
Examples of all outputs must be included as well as error recovery
procedures.  There must be a narrative description of all data system files,          •
and the narrative should describe the exact nature of the algorithm used  for          •
all the significant mass spectrometric processes.  The maintenance manuals
must include a complete set  of hardware engineering drawings, and                     •
maintenance must be described 1n terms of block diagrams, logic  diagrams,            |
flow charts, circuit descriptions, and parts lists.

    It is also assumed that  the laboratory has provided the GC/MS facility           I
with an appropriate environment including air conditioning  and other                 ™
utilities as required, trained management and operating personnel, needed
supplies, essential support  equipment, and a reasonable amount of working           •
space which allows access at the sides and rear of the system for                    •
maintenance.

    Finally, a system  logbook must be maintained throughout the  evaluation           J
period.  This must include an entry for every working day noting the  status
of the system.  This entry must be made even if the system  is not used  on           _
that day, and signed by the  responsible person.  The  logbook must include a         •
complete record of the number of gas chromatographic  injections  per  day,  the        *
number of solid probe  samples, all chromatographic column changes,  all
maintenance procedures, ^all^  requirements for service  from the manufacturer,         •
and each entry must be^sigrfed -and dated.  This information  must  be                   •
summarized  in the performance evaluation report, and  the mean numbers of gas
chromatographic injections and solid probe samples before ion source
maintenance (cleaning) must  be reported.
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                                  SECTION 2

                         SUMMARY OF PERFORMANCE TESTS


I.     Spectrum Validation Test - Uses decafluorotriphenyl phosphine (DFTPP)
      to determine whether the system gives a 70 ev electron ionizatlon
      fragmentation pattern similar to that found in the historical mass
      spectrometry data base, and the required mass resolution and natural
      abundance isotope patterns.  The spectrum of DFTPP must meet the
      criteria given in Table 2.

II.   System Stability Test - Uses DFTPP to test moderate term (20-28 hours)
      system stability.  The criteria given in Test I must be met.

III.  Instrument Detection Limit Test - Uses DFTPP to measure the full and
      valid spectrum detection limit at a defined and tolerable noise
      level.  At a signal/noise a 5, the required instrument detection
      limits are 50 nanograms for systems used in the analysis of industrial
      or municipal wastes, and 30 nanograms for systems used in the analysis
      for ambient or drinking water.

IV.   Saturation Recovery Test - Uses DFTPP and jp-bromobiphenyl to simulate
      a frequently encountered situation with real samples.  The spectrum of
      DFTPP, measured'"within two minutes after the elution of a 250 fold
      excess of p_-bromobiphenyl, must not contain significant contributions
      from the ions attributable to £-bromobiphenyl.

V.     Precision Test - Uses a variety of typical environmental pollutants to
      determine precision from filling a syringe to peak integration.  The
      mean relative standard deviation for the compounds used in the test
      which elute as narrow peaks must be 7% or less using either peak areas
      in arbitrary units or ratios of peak areas.  For broad peaks the mean
      relative standard deviation must be 13% or less.

VI.   Library Search Test - Uses data from Test V to evaluate the speed and
      completeness of the minicomputer library search algorithm.  The mean
      search time, including background subtraction, must be one minute or
      less, and all test compounds must be identified as most probable
      except isomers with very similar spectra should not be counted as
      incorrect.

VII.  Quantitative Analysis with Liquid-Liquid Extraction -.Uses a variety
      of environmental pollutants to measure quantitative SUcuracy and

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      range of 90-110% with a mean relative standard deviation of 19% or
      less using either internal or external standards.
                                                                                      I
      precision of the total analytical method.  The mean of the means of             •
      the percentages of the true values observed must be in the 68-132*              •
      range with a mean relative standard deviation of 38% or less using
      either internal or external standards.  This test also evaluates
      laboratory performance.
I
VIII. Quantitative Analysis with Inert Gas Purge and Trap - Uses a variety           —
      of compounds to measure quantitative accuracy and precision of the           .  •
      total analytical method.  The mean of the mean method efficiencies             m
      must be 70% or more.  Chloroform efficiency must exceed 90% and all
      compounds must exceed 30* efficiency.  The spectrum of £-bromofluoro-          •
      benzene must meet the criteria given in Table 7.  The mean of the              I
      means of the percentages of the true values observed must be in the
I
IX.   Qualitative Analysis with Real Samples - Uses a real sample to    '             m
      evaluate the ability of the system to deal with real sample matrix             I
      effects and interferences.  All compounds must be correctly identified         •
      except isomers with nearly identical mass spectra should not be
      counted as incorrect.  This test also evaluates laboratory performance.        •

X.    Solid Probe Inlet System Test (Optional) - Uses cholesterol to
      evaluate the spectrum validity achievable with a solid probe inlet             •
      system.  The spectrum of cholesterol must meet the criteria given in           J
      step three of the test.
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                                  SECTION 3

                           EXPERIMENTAL PROCEDURES


I.  Spectrum Validation Test

      Correct identifications of organic pollutants from gas chromatography
mass spectrometry (GC/MS) data require valid mass spectra of the compounds
detected.  This is prerequisite to the interpretation of the spectra,  i.e.,
either an empirical search for a match within a collection of authentic
spectra or an analysis from the principles of organic ion fragmentation.  A
properly operating and well tuned GC/MS is required to obtain valid mass
spectra.

      The purpose of this test is to make a quick check - about  15 minutes -
of the performance of the total operating system of a computerized GC/MS.
Thus with a minimum expenditure of time, an operator can be reasonably sure
that the GC column, the enrichment device, the ion source, the ion separa-
ting device, the ion detection device, the signal amplifying circuits, the
analog to digital converter, the data reduction system, and the  data output
system are all functioning properly.

      An unsuccessful test requires, of course, the examination  of the
individual subsystems and correction of the faulty component.  Environmental
data acquired after a successful systems check are, in a real sense, vali-
dated and of far more value than unvalidated data.  Environmental data
acquired after an unsuccessful test may be worthless and may cause erroneous
identifications.

      It is recommended that the test be applied at the beginning of a work
day on which the system will be used and also anytime there is a suspicion
of a malfunction.  A mass spectrometer which meets the criteria  of this  test
will, in general, generate mass spectra of organic compounds which are very
similar, if not identical, to spectra in collections and textbooks which
have been developed over the years with other types of spectrometers.   If
the performance criteria of this test cannot be met by the user, the system
is unacceptable for general purpose environmental measurements.

Procedure:

      1.  Make up a stock solution of decafluorotriphenylphosphine  (DFTPP)
          at one milligram per mi Hi liter (1000 ppm) concentration  in
          acetone (or a hydrocarbon solvent).  The reference compound  used

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                                                                                     I
    in this test is available from PCR, Inc., P. 0. Box 1778,                        _
    Gainesville, Florida, 32602 and may be named bis (perfluorophenyl)               •
    phenylphosphine.  This stock solution was shown to be 97+% stable                •
    after six months and indications are that it will remain usable
    for several years.  Dilute an aliquot of the stock solution to 10                •
    micrograms per milliliter (10 ppm) concentration in acetone.  The                •
    very small quantity of material present in very dilute solutions
    1s subject to depreciation due to adsorption on the walls of the                 •
    glass container, reaction with trace impurities in acetone, etc.                 |
    Therefore, this solution will be usable only in the short term,
    perhaps one week.                                                                _

2.  Select a GC column for the tests.  Any column that elutes OFTPP in              ™
    a reasonable time may be used, and several suggested columns are
    listed in Table 1.  Parameters should be adjusted to permit at                  •
    least four mass scans during elution of the DFTPP.  This will                   •
    permit selection of a spectrum that is reasonably free of
    abundance distortions due to rapidly changing sample pressure.                  •

3.  Set the preamplifier to a suitable sensitivity, set the baseline
    threshold (zero instrument), and calibrate.                                     m
                                                                                    I
4.  Prepare for data acquisition with the following variables:                      m

          Mass Range:            40-450 amu                                         •
          Scan Time:             approximately five seconds                         m
          Electron Energy:       70 ev
          Electron Multiplier:   Not to exceed that recommended by the              •
                                 supplier for the age of the device.                |

5.  Inject with a syringe 50 nanograms (five micro!iters) of the                   B
    dilute standard into the GC column.                                            •

6.  After the acetone elutes from the column and is pumped or diverted
    from the system, turn on the ionizer and start  scanning.
I
7.  Terminate the run after the DFTPP elutes, turn the  ionizer  and
    multiplier off, and plot the total  ion current profile.                        •

8.  Select a spectrum number on the front side of the GC  peak as near
    the apex as possible, select a background spectrum  number                      _
    immediately preceding the peak, and display the background                     •
    subtracted spectrum.  Some data systems permit spectrum  averaging             •
    to minimize variations 1n ion abundance due to rapidly changing
    sample pressure.  This option is acceptable, and may  be  required              •
    for narrow peaks from open tubular  columns.                                    I

9.  The mass spectrum can be output in  various ways  including a plot              •
    of the full spectrum on the plotter or cathode ray  tube  or  a print            |
    of the full spectrum on a printer or cathode ray tube.
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                TABLE 1.  SUGGESTED GC COLUMNS AND  CONDITIONS

Dimension (Type)   Packing                  Flow Rate     Temp.    R. Time

2m x 2 mm ID       1.95% QF-1 plus          30 ml/min       180     4 min
   (Glass)         1.5% OV-17 on
                   80/100 mesh Gas-Chrom Q

2m x 2 mm ID       3% OV-1 on 80/100        30 ml/min       220     5 min
   (Glass)         mesh Chromosorb W

2m x 2 mm ID       5% OV-17 on 80/100       30 ral/m1n       220     5 rain
                   mesh Chromosorb W

2m x 2 mm ID       1% SP2250 on 100/120     30 ml/min       170     5 min
   (Glass)         mesh Supelcoport

30m x .25mm ID     Wall coated SP 2100     2-5 ml/min     40,240    10 min
   (Glass)

The spectrum obtained on the test system must contain  ion abundances within
limits given for the key ions in Table 2 (1).

      If the relative abundances are not within the limits  specified,  the
appropriate adjustments must be made, I.e., resolution,  source potentials,
calibration of the mass scale, source magnet position, etc. The  manufac-
turer may need to be consulted for assistance in this  adjustment. Repeat
this test until satisfactory results are obtained.
 TABLE 2. DECAFLUOROTRIPHENYLPHOSPHINE KEY  IONS  AND  ION ABUNDANCE CRITERIA.-


           Mass           Ion Abundance Criteria
 •                51            30-80% of Mass 198


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            68        -   Less than 2% of Mass 69
            70           Less than 2% of Mass 69
           127           30-70% of Mass 198
           197           Less than 1% of Mass 198
           198           Base Peak,  100% Relative  Abundance
           199           5-9% of Mass 198
           275           10-30% of Mass 198
           365           At  least 1% of Mass  198
           441           Present, but less than Mass  443
           442           Greater than 40% of  Mass  198
           443           17-23% of Mass 442
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I       ^-Criteria  for  masses  51  and  127 are modifications of previous values (1)
       based  on new inter laboratory data.

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II.  System Stability Test                                                           -

    The purpose of this test is to evaluate moderate term system stability.          ™
Repeat the test described in Section I after 20-28 hours.  Do not make any
adjustments or recalibration of the system between tests except routine              •
overnight procedures.  The abundance criteria in Table 2 must be met.  If            I
these criteria are not met, the system is too unstable for routine use and
must be repaired.                                                                    •

III.  Instrument Detection Limit Test

    This test is to determine the smallest quantity of standard test                 I
material that can be injected into the GC/MS system that gives an acceptable         *
spectrum meeting the criteria in Table 2, but has a sufficiently low  level
of background signals to allow correct interpretation of that spectrum if            •
the sample was an unknown.  A spectrum of a test compound contaminated with          I
background signals to the extent of about 10X or more of Its total ion
abundance is considered to be difficult or impossible to interpret                   •
correctly.  This judgment is somewhat variable because 102 background dis-           |
tributed among a large number of small ions may be acceptable, but a
distribution among a few large ions will be unacceptable.  Therefore, a              —
signal to noise ratio based on a selection of six ions is used to evaluate           •
the detection limit.  This also allows a relatively simple calculation of            •
the ratio.

    In a GC/MS system there are a number of potential sources of background          •
signals (chemical noise) including septum bleed, stationary phase bleed,
vacuum system background from various physical components, and ion source            •
contamin- ation.  Furthermore, all signals are dependent on GC" column               |
efficiency, enrichment device efficiency, vacuum system efficiency,  ioniza-
tion efficiency, ion transmission efficiency, and detector gain.  Therefore,         —
this test is highly sensitive to the specific system.configuration (specific         •
GC column, etc.; and the current condition of that system, e.g., condition           *
of the GC column, extent of contamination in the ion source, extent  of
contamination of the quadrupole rods if a quadrupole instrument, and                 •
condition of the electron multiplier.  The state of the system should be             I
documented as part of the records of the instrument detection limit  test.

Procedure:            ,                                                               g

    1. Make three dilutions of the stock solution of DFTPP described in  Test         —
       I.  The dilutions should have the concentrations of five micrograms          •
       per milliliter, one microgram per milliliter, and one-tenth of a             *
       microgram per milliliter.

    2. Follow the basic procedures given in Test I and make  the following           I
       series of injections:
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           Amount Injected        Volumes and Standards

           20 nanograms          4 ul of 5 ug/ml standard
           10 nanograms          2 ul of 5 ug/ml standard
            5 nanograms          1 ul of 5 ug/ml standard
            1 nanogram           1 ul of 1 ug/ml standard
          100 picograms          1 ul of 0.1 ug/ml standard

3. List the masses, relative abundances, and/or absolute abundances
   (intensities) of the background subtracted spectra of DFTPP.  Sub-
   tract the background spectra as described in Test I.  If necessary
   use an extracted ion current profile to locate the GC peak.  Discard
   all spectra that do not meet the criteria in Table 2.  From the
   remaining spectra discard those that do not display at least six
   non-OFTPP ions with relative abundances greater than 5%.   If
   additional dilutions or measurements are necessary, do them.  Table 3
   contains all DFTPP ions over 3% relative abundance and Table 4
   contains a group of common background ions.

4. For each of the qualified spectra compute the ratio R as follows:

                           Lf DFTPP)
                           [BACKGD)

   where:

           (DFTPP) « the summation of the abundances of  the  ions  at
           masses 127, 255, 275, 441, 442 and 443

           (BACKGD) « the  summation of the abundances  of the six  most
           abundant (but each over 5% relative abundance)  non-OFTPP
           background ions

   Prepare a plot of R values as a function of amount  injected.   The
   instrument detection limit defined in this test  is  for the complete,
   valid spectrum with a defined level of acceptable noise.   This
   detection limit is the  amount injected that gives an  R value of
   five.  If sufficient points  are available, a  good estimate of  the
   instrument detection limit may be obtained from  a first or second
   order regression on this data.

   The rationale for the selection of an R value of five is  consistent
   with the previous statement  that background ions should be less than
   about 10% of the total  ion abundance in an interpretable  spectrum.
   The average relative abundance of the six DFTPP  ions  used to compute
   R is in the 25-35% range.  For an R value of  five the average
   relative abundance of the six background ions will  be in  the 5-7%
   range, and it is estimated that all background  ions under these
   conditions will be less than 10% of the total ion abundance.

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       TABLE 3.  IONS OVER 3% RELATIVE ABUNDANCE OBSERVED                      •
             '   IN THE 70 ev MASS SPECTRUM OF DFTPP                           |


 AMU              .    INTENSITY        PERCENT OF TOTAL INTENSITY             I

 50.0                    8.11                  1.11
 51.0                   34.60                  4.74                           •
 69.0                   32.93                  4.51                           I
 74.0                    3.10                  0.42
 75.0                    4.53                  0.62                           •
 77.0                   34.84                  4.77                           I
 78.0                    3.10                  0.42
 93.0                    3.10                  0.42                           _
 99.0                    3.81                  0.52                           I
107.0                   10.97                  1.50                           •
110.0                   20.76                  2.84
117.0                    6.44                  0.88                           •
127.0                   37.70                  5.16                           1
128.0 -  -  .      -  -    3.10      -            0.42
129.0                   12.88                  1.76                           •
167.0                    4.05                  0.55                           •
168.0                    4.77                  0.65
186.0                   13.12                  1.79                           _
187.0                    3.81                  0.52                           I
198.0                  100.00                  13.69                           •
199.0                    7.15                  0.98
205.0                    5.01                  0.68                           •
206.0                   20.28                  2.77                           I
207.0        -           4.53                  0.62
217.0                    5.01                  0.68                           .
221.0                    4.29                  0.58                           I
224.0                   11.21                  1.53                           "
227.0                    3.81                  0.52
244.0                    8.11                  1.11                           I
255.0                   49.16                  6.73                           •
256.0                    7.39                  1.01
274.0                  •  4.29                  0.58                           •
275.0                   23.15                  3.17                           I
276.0                    3.81                  0.52
296.0                    5.01                  0.68                           m
423.0                    3.34                  0.45                           I
441.0                    9.30                  1.27                           "
442.0                   69.45                  9.51
443.0                   12.88                  1.76                           I



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                   TABLE 4.   COMMON BACKGROUND IONS IN GC/MS SYSTEMS


            Masses                   Sources

            41,43,55,57,             Saturated hydrocarbons and
            69,71,81,83,             unsaturated hydrocarbons -
            85,95,97,99              cyclic and open chain-many sources

            149                      Phthalate esters used as plasticizers
                                     in tubing, etc.

            73,101,135,197,207       Methyl and phenyl silicone
            259,345,346,355           polymers used in stationary
                                     phases, diffusion pump oil, etc.

            169,251                  Polyphenyl ether diffusion
                                     pump oil

         The required instrument detection limits, at an R value of five, are 50
     nanograms for systems used in the analyses of industrial or municipal
     wastes, and 30 nanograms for systems used in analyses of ambient or drinking
     waters.  These limits were obtained from considerations of EPA recommended
     sample sizes and concentration factors.  If a system cannot meet these
     criteria, maintenance or repair is required.  Particular attention should be
     given to those items mentioned in the second paragraph of this test.

         Observed detection  limits with this test are as follows:

         1. A Finnigan 3200 equipped with a Varian 1400 GC, a packed 1% SP 2250
            Column (Table 1), a Systems Industries RIB interface, and a POP-8
            datasystem (disk) gave a detection limit of five nanograms.

         2. A Finnigan 4000  with a Finnigan 9610 GC, a packed 1% SP 2250 column
•           (Table 1), an INCOS interface, and an INCOS datasystem (Nova 3, disk)
•           gave a detection limit of 25 nanograms.

     IV.  Saturation Recovery Test
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         The purpose of this test is to evaluate the ability of a system to
     measure the spectrum of a test compound at a low level immediately after a
     relatively large quantity of another compound entered the system.  This
     situation occurs frequently in real environmental samples, especially waste
     samples where a very large concentration of one component may saturate the
     detector, and within a few minutes or less a very small quantity of a
     compound of interest may enter the detector.

     Procedure:

         1. Prepare an acetone solution containing five milligrams per mi Hi liter
            of £-bromobiphenyl and 20 micrograms per mi Hi liter £f DFTPP.  A
            second solution containing approximately 50 micrograms per milliliter

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       of each is optional and may be useful to optimi2e chromatographic              •
       conditions.                                                                    I

    2. Establish GC conditions such that the DFTPP elutes within two minutes          •
       after the elution of the £-bromobiphenyl.  These conditions were               |
       achieved with a 6' x 2 mm 10 glass column packed with 1% SP2250 on
       Supelcoport (100/120 mesh) using a flow of 30 ml of helium per minute
       with the initial column temperature at 120°C and programming to                I
       230°C at 10° per minute.  The £-bromobiphenyl eluted at 110                    •
       seconds and the DFTPP at 210 seconds.  This test is carried out using
       the same basic operating parameters given in Test I.                           •

    3. Inject two microliters of the standard solution containing the 250:1
       ratio of p-bromobiphenyl to DFTPP.  Plot the DFTPP spectrum as in              •
       Test I.  Each of the ions at masses 152, 232, and 234, which are the           •
       three most abundant in the spectrum of £-bromob1phenyl, must be below
       5% relative abundance in the background subtracted spectrum of DFTPP.

V.  Precision Test                                                                    •

    The purpose of this test is to measure the precision of the GC/MS system          •
in quantitative analysis using continuous, repetitive measurement of spectra.         I
This test evaluates precision from filling a syringe to integration of the
peak area for a specific quantitation ion.  The entire test should be                 •
carried out on the same day by the same technician.  The application of an            •
automatic sample changer in this test is required if it will be used for
normal sample, processing.  This should be documented in the test results.
If acceptable precision cannot be obtained with this test, the precision of           •
a complete anaytical method may also be unacceptable.                                 •
         *
Procedure:                                                                            •
                                                                                   *   •
    1. Select a group of seven or more compounds, and prepare a standard
       solution in acetone that contains the entire group.  Some recommended          «
       compounds are in Table 5, and the concentration of each should be 20           •
       micrograms per mi Hi liter.  This group of compounds must include a
       chlorinated hydrocarbon that may decompose on a hot metal surface and
       a polycyclic aromatic hydrocarbon with a molecular weight greater              •
       than 200.  For compounds amenable to the inert gas purge and trap             *
       procedure, prepare the standard solution in methanol at the same
       concentration.  The purge and trap mixture must include chloroform,           •
       bromoform, .syjn-tetrachloroethane, and p-bromofluorobenzene.  Some             |
       recommended compounds are 1n Tables 9-12.  This test may be conducted
       with either or both groups of compounds.                                      •




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  TABLE 5.  PRECISION STATISTICS FOR TEN PRIORITY POLLUTANTS PLUS OCTAOECANE
COMPOUND


1,3-OICHLOROBENZENE

NAPHTHALENE

1,2,4-TRICHLOROBENZENE

£-OCTADECANE

DIMETHYL PHTHALATE

DI-ji-BUTYL PHTHALATE

N-NITROSOOIPHENYLAMINE

HEXACHLOROBENZENE

PYRENE

CHRYSENE

BENZO(A)PYRENE
INTEGRATION
    MASS
    146

    128

    ISO

    254

    163

    149

    169

    284

    202

    228

    252
PEAK*
TYPE
  N

  N

  N

  N

  N

  N

  N

  N

  N

  B

  B
MEAN            (S/MEAN AREA)
AREA       S        *100
 6771     278       4.1

18077     375       2.1

 5412     195       3.6

  345      15       4.2

13540     501       3.7

21770     364       1.7

 6460     228       3.5

 4027     139       3.4

18107     607       3,4

10345     636       6.2

 9518     681       7.2
   * narrow; B * broad (see text for definitions)


    2.  Select an appropriate GC column.  For compounds similar to  those  in
        Table 5, the columns in Table 1 are  satisfactory.   For compounds,
        amenable to purge and trap procedures, two acceptable columns  are  an
        8 ft. stainless steel or glass column packed with  1% SP-1000 coated
        on 60/80 mesh Carbopack B or packed  with 0.2%  Carbowax 1500 coated
        on 60/80 mesh Carbopack C.  Prepare  for data acquisition  with  the
        following variables:

        mass range:  35-350 amu (For purge and trap compounds use 20-260  amu)
        scan time:  approximately six seconds (two or  three seconds with  open
                    tubular columns)
        electron energy:  70 ev
        electron multiplier:  not to exceed  that recommended by the
                              supplier for the age of  the  device.

    3.  Inject with a syringe or automatic sample changer  four microliters
        (80 nanograms of each compound) of the standard sol«$ion  and acquire
        data until all compounds have eluted from the  column.  Save the data

                                      13

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        file  on  the data system and repeat the injection  a minimum of four
        times, saving the data files 1n  each  case.                                       I

    4.   Plot  the total ion current profiles,  and use  a quantitation program
        to  integrate peak areas in arbitrary  units  (usually                              •
        analog-to-digital counts)  over a specific quantitation  mass for each            |
        compound In each data file.  Precision may  be evaluated using either
        the peak areas in arbitrary units or  ratios of peak  areas.  The                 •
        former gives a precision representative of  external  standardization,            •
        and the  latter a precision representative of  internal
        standardization.  There will be  no significant difference 1n the
        results  using the two methods 1f the  system 1s operating properly              •
        and acceptable syringe filling and injection  techniques are used.              •
        It  is recommended that calculations be carried out using both
        methods  for comparison of  results, but the  minimum requirement 1s              •
        that  precision be evaluated using the method  that corresponds to the           |
        standardization procedure  used in the laboratory  for environmental
        samples.                                                                   •    m

     •   Table 5  1s  an example of data from five replicate syringe injections
        of  80 nanagrams of each compound using a Finnigan 3200  and a POP-8
        based data  system.  The mean areas are in analog-to-digital                   I
        converter units and the standard deviations (S) were'computed using           •
        the equation below.  The last column  in Table 5  1s the  relative
        standard deviation which is (S/mean area)*  100.   Table  6 contains             •
        the results of computations with exactly the  same raw  data as in              |
        Table 5, but using ratios  of areas as in Internal standard
        calibrations.  The response factor (RF) is  defined "in  test VII, and           m
        the mean response factors  are shown in Table  6.   The compound                 •
        di-n-butylphthalate was selected as the internal  standard because 1t          m
        showed the  smallest variation 1n peak area  (1.7%, Table 5) and
        eluted near the mid-point  in the chromatogram.   The  standard                  I
        deviations  and relative standard deviations were computed as in               •
        Table 5.

                   N      * _ (JL -    ~                                         1
       S »       ",r,  ca 1
                             .
                           N (N-l)

         where:
               S * the standard deviation

               N * the number of measurements
                   for each compound

               Area = the integrated 1on abundance of the
                      quantitation mass
I
    The compounds designated as having narrow peak types in Tables 5 and 6
had widths at half height of 45 seconds or less.  The mean relative standard        •
                                      14

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          TABLE 6.  PRECISION  STATISTICS  USING AN  INTERNAL STANDARD
COMPOUND

1,3-DICHLOROBENZENE
NAPHTHALENE
1,2,4-TRICHLOROBENZENE
J1-OCTAOECANE
DIMETHYL PHTHALATE
DI-£-8UTYL PHTHALATE
N-NITROSODIPHENYLAMINE
HEXACHLOROBENZENE
PYRENE
CHRYSENE
BENZO(A)PYRENE
INTEGRATION   PEAK1
    MASS      TYPE
    146
    128
    180 -'
    254
    163
    149
    169
    284
    202
    228
    252
N
N
N
N
N
N
N
N
N
B
B
          MEAN
           RF
0.3112
0.83048
0.2486
0.0158
0.62202
1.00000
0.2968
0.1850
0.83171
0.4751
0.4370
                 (S/MEAN RF)
            S        *100
0.01512
0.017250
0.008571
0.000838
0.022980
0.00000
0.01008
0.005899
0.023110
0.02619
JO. 0275
4.9
2.1
3.4
5.3
3.7
0
3.4
3.2
2.8
5.5
6.3
                                      15

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                                                                                     I
deviation for the data in Table 5 1s 3.32, and the corresponding mean from
Table 6 is 3.6 2.  Therefore there was no significant difference in the              I
precision of external and internal standardization.  The requirement of this         •
test is that the mean relative standard deviation of data from narrow peaks
be 7% or less.  This requirement is based on the general observation that            •
data from interlaboratory comparisons is usually about a factor of two more          |
variable than single laboratory data, and this 1s a reasonable requirement
for an acceptable system.                                                            _

    The last two compounds 1n Tables 5 and 6 gave broader peaks with peak            B
widths at half height of more than 45 seconds.  Measurements of these are
more variable because of the changing baseline during temperature                    •
programming and other factors,  pie mean relative standard deviations from           •
Tables 5 and 6 are 6.72 and 5.^'respectively, and internal standardization
may have some slight advantage for these peaks but there are too few data            •
points to judge the significance of this.  The requirement of this test  is           |
that the mean relative standard deviation of data from broad peaks be 132 or
less.  Again the rule of thumb on interlaboratory data was used to establish         _
this requirement.                                                                    I

    If this test is conducted with compounds amenable to the Inert gas purge
and trap procedure, the compound £-bromofluorobenzene must be included in            •
the mixture.  This compound is a secondary spectrum validation compound              •
which is used with GC columns that do not elute DFTPP.  Therefore, after a
purge and trap column is installed for this test p_-bromofluorobenzene may be         •
used as a daily check on spectrum validity.  The ion abundance criteria  for          |
p_-bromofluorobenzene are 1n Table 7, and these are consistent-with the OFTPP
criteria in Table 2.                                                                 -

      TABLE 7.  £-BROMOFLUOROBENZENE KEY IONS AND  ION ABUNDANCE CRITERIA            •

         Mass                        '  Ion Abundance Criteria                        I

          50                           20-402 of the base peak
          75                           50-702 of the base peak                       •
          95                           base peak,  1002 relative                      |
                                       abundance
          96                           5-92 of the base peak                         _
         173                           less than 12 of the base peak                 •
         174          :                 greater than 502 of the base peak            ™
         175                           5-92 of mass 174
         176                           greater than 502 of the base peak            I
         177                           5-92 of mass 176                              •

VI.  Library Search Test                                                             •

    Minimum requirements for the  library search  are the availability  of  the
EPA/NIH database which  Is distributed through the  National Bureau  of                 .
Standards.  The  searchable database  may be a  subset of  the EPA/NIH database,        •
but the subset must contain at  least 10,000 spectra of general and                  m
environmental  interest  and the  Chemical Abstracts  Service  (CAS) registry
numbers for each compound.  Programs must be  available  to  allow the operator        I

                                     16
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to submit background corrected spectra to the  library search, and receive a
printed report of the search results.  The spectra from one of the
experiments in Test V should be submitted to the library search system.
Each compound must be identified as the most probable by the library search,
except isomers that may have very similar 70 ev El mass spectra should not
be counted as incorrect.  The mean search time, including the time for
background subtraction, should be one minute or less.  Printed reports
should include CAS numbers.  During this test make several deliberate
typical operator errors, such as entry of an incorrect command and a
non-existent file name.  The data system should respond with an intelligible
error message, and return to a logical continuation point.

VII.  Quantitative Analysis with Liquid-Liquid Extraction

    This test uses a variety of environmental pollutants to measure quanti-
tative accuracy and precision of the total analytical method, but without
the complications of real sample matrix effects.  The test is designed for
laboratories that conduct quantitative analyses of water samples with GC/MS
using continuous repetitive measurement of spectra.  Therefore, laboratories
dealing in other media should design a similar test based on some standard
reference material.  The principal difference between this test and Test V,
the precision test, is the consideration of potential errors and variations
due to:  (a) extraction of the compounds from  a clean water matrix; (b)
concentration of the extract to a small volume; and (c) standardization of
the measured areas in terms of the concentration of the original sample in
micrograms per liter.  This is one of the tests that goes beyond equipment
performance, and may be used to evaluate the performance of  laboratories
using GC/MS for organics analysis.

    It is recommended that the same standard solution of seven or more
compounds that may have been prepared for the precision test (Test V) be
used in this test since retention information  is already available, and the
concentrations are in an acceptable range.  However, new standards may be
used and the seven or more compounds should be at the 20 microgram per
mi Hi liter level in acetone.

Procedure:

    1.  Add 250 microljters (five micrograms of each compound) of the mixed
        standard solution in acetone to each of a minimum of five liters  of
        clean water.  This aqueous solution is called a  laboratory control
        standard.  Set aside one additional liter of clean water as a
        reagent blank.

    2.  Carry out the extractions according to the established procedures
        (2,3,4).  The methylene chloride extract must be concentrated to  0.5
        milliliter.  The blank should be measured first by itself, and  if
        significant contamination is found, correct the problems before
        proceeding with this test.  See the references cited above for
        information on the interpretation of blanks.
                                      17

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•             With an internal standard P  1s computed with the equation below
*             which assumes the response factors  are defined  as  above:
                     area (concentrated extracts) *100
                          area (external standard)
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             p s      area (concentrated extract)   *100
                        area (internal standard)  *RF

    Table 8 shows precision and accuracy data obtained for eight compounds
extracted from clean water with methylene chloride and measured with GC/MS
using a single external standard.  The GC/MS was a Finnigan model 3200 with
a PDP-8 based datasystem.  One difference between the data in Table 8 and
the procedures described in this test is that the data in Table 8 represents
duplicate extractions and measurements at four different concentration
levels between 15-200 micrograms per liter for each compound.  Figures 1 and
2 show control charts which contain all eight P values for each of two of
the compounds.  This is a recommended method (5) of displaying precision and
accuracy data.  Charts should be labelled as in Figures 1 and 2.  General
experience shows that P values measured over a concentration range of one or
two orders of magnitude are often concentration independent within the
precision of the method.

    The mean of the P values in Table 8 is 84%.  Therefore, the requirement
of this test is that the mean of the mean P values of the compounds used in
this test must be in the range of 68-132%.  Again, as in Test V, the
expectation is that multi-laboratory data will usually be about a factor of
two more variable than single laboratory data.  The mean relative standard
deviation from Table 8 is 19%, and the requirement of this test is that the
mean relative standard deviation be 38% or less.

VIII.  Quantitative Analysis with Inert Gas Purge and Trap

    This test uses a variety of environmental pollutants to measure
quantitative accuracy and precision of the total analytical method, but
without the complications of real sample matrix effects.  The test  is
designed for laboratories that conduct quantitative analyses of water
samples with GC/MS using continuous repetitive measurement of spectra.
Therefore, laboratories dealing in other media should design a similar test
based on some standard reference material.  The principal difference  between
this test and Test V, the precision test, is the consideration of potential
errors and variations due to:  (a) purging of the compounds from a  clean
water matrix; (b) trapping and desorption of the compounds; and  (c)
standardization of the measured areas in terms of the concentration of  the
original sample in micrograms per liter.  This test is required to  evaluate
purge and trap equipment that is delivered as an  integral part of  a GC/MS
system, or other purge and trap equipment that  is interfaced to the GC/MS
system.

    The series of experiments in this test is used to generate three  key
pieces of information about purge and trap performance:


                                     19

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      TABLE 8.  PRECISION AND ACCURACY DATA FOR LIQUID-LIQUID EXTRACTION
                     WITH GC/MS AND AN EXTERNAL STANDARD                               |

                          INTEGRATION     MEAN              (S/MEAN P)                 •
COMPOUND                     MASS          P          S        *100                    f
NITROBENZENE                 123           94       8.8          9.4                   -
1,2,3-TRICHLOROBENZENE       180           85      13           15                     •
NAPHTHALENE                  128           73      18           25                     |
ACENAPHTHYLENE               152           83      15           18
N-NITROSODIPHENYLAMINE       169           89      19           21                    |
FLUORANTHENE                 202           80      19           24                    _
PYRENE                       202           83      19           23                    •
n.-BUTYLBENZYLPHTHALATE       206           86      17           20                    |

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1
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1

1120
,
• 110-
100'
	
2i 90-
1 1 "
• u
e 70'
• 60'
1
40-
1

1
1
• Figure 1
1

1




r
Compound: nitrobenzene ' Data acquisition : 35 - 400amu
Range: 50 - 200ug/l Quantitation: mass 123. one
. , .. ,.u /», external standard
Method: extraction. CH2C12
Relative standard deviation: 9%

o
o
O O
0
o



8/31 8/31 8/31 8/31 9/5 9/5 9/5 9/5
Experiment Date (1978)


, Control chart for nitrobenzene in clean water.

21


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    140
       Compound: pyrene
       Range: 15 • 130pg/l
       Method: extraction. CH2C12
       Relative standard deviation: 23%
                                     Data acquisition: 35 - 400 amu
                                     Quantitation: mass 202. one
                                                 external standard
    130H

    120'

    no
i
    100

  £90<
I  "~
,  I 80.
I  o
S  S 70
'  C
I    60

j    50
i
I    40

    30

    20
                                                        MEAN * 3S
                                                       MEAN + S
                                                       -MEAN = 83.4 (S-19)
                                                       MEAN - S
                                                        MEAN - 3S
         8/31 8/31 8/31 8/31  9/5 9/5  9/5 9/5
                   Experiment Date (1978)
Figure 2.  Control chart for pyrene  1n  clean  water.
                                    22
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    (a) Method efficiency for test compounds by comparison of the measured
        quantity from syringe injection into the GC with the quantity
        measured after purging, trapping, and desorption.  Because of the
        method of calibration used in the purge and trap procedure high
        method efficiency as defined above  is not necessary for acceptable
        precision and accuracy.  However, high method efficiency is required
        for acceptable sensitivity, and low method efficiency will result  in
        unacceptable detection limits.  Also in the case of real samples,  a
        low method efficiency combined with an unfavorable matrix effect
        could render the method totally useless.

    (b) Precision of the overall purge, trap, desorption, and 6C/MS analysis.

    (c) Accuracy of the overall purge, trap, desorption, and GC/MS analysis
        in terms of the percentage of the true value found in laboratory
        control standards.

    All the above information may be obtained from the  same set of data.   It
is recommended that the same standard solution of seven or more compounds
amenable to purge and trap that was recommended for the precision test  (Test
V) be used in this test since retention information may be already
available, and concentrations are in an acceptable range.  However, new
standards may be used, and the seven or more compounds  should be at the 20
micrograms per milliliter level in methanol.  The purge and trap mixture
must include chloroform, bromaform, s^m-tetrachloroethane and
£-bromofluorobenzene.

Procedure:

    1.  Select an appropriate column (see Test V) and prepare for data
        acquisition using the GC/MS operating parameters given  in Test  V.   .

    2.  Add five microliters (100 nanograms of each compound) of the  mixed
        standard in methanol to each of a minimum of five aliquots of low
        organic water.  Purge and trap samples may be 5 ml to 25 ml,  but  5
        ml is recommended for optimum method efficiency.  This  aqueous
        solution is called a laboratory control standard.

    3.  Carry out the purge and trap according to the established procedures
        (2,3,4) at ambient temperature.  A  low organic  water  blank  should  be
        measured first and at occasional intervals to detect  instrument
        contamination.  If significant contamination is found,  correct  the
        problems before proceeding with this test.  See references cited
        above for information on the interpretation of  blanks.

    4.  Purge, trap, desorb, and obtain GC/MS data from a minimum of  five
        laboratory control standards and save all the data files.  At about
        the midpoint of the purge and trap  analyses, inject with a  syringe
        five microliters (100 nanograms of  each compound) of  the mixed
        standard in methanol into the purge and trap GC column.  Acquire


                                     23

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                                                                                  I

    GC/MS data using the same acquisition parameters used for purge and           •
    trap analyses.                                                                I

5.  Plot the total 1on current profiles, and use a quantltatlon program           •
    to Integrate peak areas 1n arbitrary units (usually analog-to-                |
    digital converter counts) over a specific quantitation mass for each
    compound in each data file.                                                   —

6.  Method efficiency must be evaluated by comparing the measured areas           •
    from direct GC Injection with the corresponding areas from the
    purge, trap, and desorption experiments.  Internal standards cannot           •
    be used because method efficiencies for various compounds are not             •
    yet known, and comparable response factors cannot be computed for
    direct injection and purge/trap/desorption.                                   •

    Prepare a table similar to Table 9 which shows data obtained with  a
    Finnigan model 3200, a POP-8"data system, and a Tekmar model, LSC-1           —
    purge and trap device with a 25 ml sample container.  The equation           •
    used to compute method efficiencies (E) is shown below.  The minimum          •
    requirement of this test is that the mean of the mean method
    efficiencies of the compounds used in this test be 703J or more.  The          •
    chloroform efficiency must exceed 90X and all compounds must be               I
    recovered with at least 30% efficiency.  Also the spectrum obtained
    from p-bromofluorobenzene must meet the ion abundance criteria given          •
    in Table 7.  If these requirements cannot be met, the system is               |
    unacceptable for quantitative analyses and needs repair or
    redesign.  One critical method variable that may be optimized is the          —
    purge gas flow rate.                                                          I
     *

           P    •      area (after purge and trap)
           *           area (direct injection)

7.  Precision and accuracy data may be obtained by choosing one of the           •
    experiments in the purge and trap set as a standard, and computing           |
    the percentages of the true values (P) measured in the other
    laboratory control standards.  This is consistent with the  standard           _
    method of calibration used with the purge and trap method.  The               I
    experiment chosen as the standard may either be treated as  an                 "
    external standard, or may be used to compute response factors for  an
    internal standard calibration.  Table 10 shows the data from  the             •
    method efficiency determination recomputed by Ignoring the  direct             I
    injection result, and using one-of the purge and trap experiments  as
    an external standard. -The equation used to compute the percentages         "•
    of the true values (P) is  as follows:                                         |

              p «       area (after purge and trap)   *,QQ                        _
                        area (external standard)                                  •
     The  standard  deviation  of  P  and  relative  standard deviation were
     computed  as described  in Test V.   The mean  of the P values in Ta
     10  is  95% and the  mean  relative  standard  deviation is 9.4S.  The

                                  24
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TABLE 9. METHOD EFFICIENCIES FOR SOME PRIORITY POLLUTANTS
PLUS £-BROMOFLUOROBEN2ENE

COMPOUND

CHLOROFORM
CARBON TETRACHLORIDE
BROMOOICHLOROMETHANE
TRICHLOROETHYLENE
DIBROMOCHLOROMETHANE

BROMOFORM
TETRACHLOROETHYLENE
Sym-TETRACHLOROETHANE
£-BROMOFLUOROBENZENE










INTEGRATION MEAN AREA AREA DIRECT
MASS PURGE/TRAP INJECTION

83 2883 3001
117 2289 2314
83 2925 3280
130 1474 1653
129 1572 2343

173 1241 2788
166 1737 2102
83 1032 3071
174 1542 2200







.
25

MEAN METHOD
EFFICIENCY^)

96
99
89
89
67

45
83
34
70











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TABLE 10. PRECISION AND ACCURACY DATA FOR THE PURGE AND TRAP
ANALYSIS WITH GC/MS AND AN EXTERNAL STANDARD
INTEGRATION . MEAN (S/MEAN P)
COMPOUND MASS P S *100
CHLOROFORM 83 92 8.8 9.5
CARBON TETRACHLORIDE 117 97 7.9 8.2
BROMODICHLOROMETHANE 83 96 7.2 7.5
TRICHLOROETHYLENE 130 94 7.4 7.9
DIBROMOCHLOROMETHANE 129 98 4.4 4.5
8ROMOFORM 173 96 5.2 5.4
TETRACHLOROETHYLENE 166 96 14 14
S^-TETRACHLOROETHANE 83 100 14 14
£-BROMOFLUOROBENZENE 174 90 12 14
-
.-





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        requirement of this test is that the mean of the mean P values of
        the compounds used  in  this test must be  in  the range of 90-110%.
        This is based on the genera] rule, described in Test V, that data
        from inter laboratory comparisons is usually about  a factor of two
        more variable than  single laboratory data.  The mean relative
        standard deviation must be 19% or  less on the same basis.

        The percentages of the true values (P) may  also be computed by
        selecting one compound in the test mixture  as an internal standard,
        and using one of the purge and trap experiments to establish
        response factors as defined in Test VII.  The percentages of the
        true values (P) in the other laboratory control standards are
        computed as follows (the terms have the same meaning defined in Test
        VII):

              0 _       area (x) * 100
                        area  (s) *RF

    Table 11 shows the method efficiency data recomputed with
£-bromofluorobenzene as the internal standard.  Response factors  were
established with the same purge and  trap experiment that was  used  as  an
external standard for the computations  in Table 10.  Table 12  shows the same
data recomputed with dibromochloromethane as an internal standard.   Again,
response factors were established with  the same purge  and trap experiment
that was used as an external  standard for the computations in  Table 10.

    The internal standard calculations  reveal that the percentages  of  the
true values observed and the  relative standard deviations are  a function  of
the internal standard selected.  The compound £-bromofluorobenzene  eluted
late in the chromatogram after temperature programming,  and measurements  of
it were more variable because of this and other factors.  This is reflected
in the mean of the mean P values from Table 11 of 108% and the mean relative
standard deviation of 12%.  The compound dibromochloromethane  showed the
least variation in the external standard data (Table 10) and is an  excellent
internal standard.  The mean  of the mean P values from Table 12 is  97% with
a mean relative standard deviation of 6.5%.  This illustrates  that  care must
be exercised in the selection of an internal standard  because  of  the
potentially significant impact on the observed precision and accuracy. The
individual P values may also  be charted as in Figures  1 and 2  to  provide  a
graphic presentation of the data.

IX.  Qualitative Analysis with Real Samples

    The purpose of this test  is to evaluate the ability of the SC/MS system,
laboratory, and sample preparation methods to deal with natural background,
interferences, and sample matrices found in real environmental samples.   The
tsst is limited to qualitative analyses because of the unpredictable
quantitatvie effects of the sample matrix.  This is one of the tests that
goes beyond equipment performance, and  it may be used  to evaluate the
performance of laboratories using GC/MS for organics analysis. The test  is
designed for laboratories that conduct  qualitative analyses of water samples
with GC/MS using continuous,  repetitive measurement of spectra.

                                      27

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TABLE 11. PRECISION AND ACCURACY DATA FOR THE PURGE AND TRAP
ANALYSIS WITH GC/MS AND THE INTERNAL STANDARD £-BROMOFLUOROBENZENE
INTEGRATION MEAN - (S/MEAN P)
COMPOUND MASS P S *100
CHLOROFORM 83 103 13 13
CARBON TETRACHLORIDE 117 108 12 11
BROMODICHLOROMETHANE 83 > 107 12 11
TRICHLOROETHYLENE 130 105 12 11
DIBROMOCHLOROMETHANE 129 110 11 10

BROMOFORM 173 108 12 11
TETRACHLOROETHYLENE 166 107 13 12
Sym-TETRACHLOROETHANE 83 112 19 17
£-BROMOFLUOROBENZENE 174 100 0 0







-
28
1
1
1

1
1

1



1

1
1
1
1
1
1
1
1
1
1

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I
•TABLE 12. PRECISION AND
ANALYSIS WITH GC/MS AND THE
ACCURACY DATA FOR THE PURGE AND TRAP
INTERNAL STANDARD DIBROMOCHLOROMETHANE
1 INTEGRATION MEAN (S/MEAN P)
COMPOUND
1
• CHLOROFORM
• CARBON TETRACHLORIDE
BROMODICHLOROMETHANE
| TRICHLOROETHYLENE
DIBROMOCHLOROMETHANE
• BROMOFORM
• TETRACHLOROETHYLENE
Sym-TETRACHLOROETHANE
| 2-BROMOFLUOROBENZENE
1
1
1
1
1
1
1
1


MASS

83
117
83
130
129
173
166
83
174










P S *100

94 5.8 6.2
98 4.3 4.4
98 3.7 3.7
95 3.8 4.0
100 0 0
98 2.0 2.0
98 9.8 10
101 11 11
92 9.7 11
-







29


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                                                                                       I
Procedure:

    1.   Acquire appropriate quality control samples.  These should be 1n               |
        sealed glass ampoules containing one to fifty organic compounds
        dissolved in acetone, methanol, or some other miscible organic          .       •
        solvent.  The concentration levels should be suitable for the                  I
        preparation of aqueous samples in the 10-500 micrograms per liter              ™
        range by addition of 250 or fewer microliters of the organic
        solution to 5 to 1000 milliliters of an environmental sample.                  •
        Instructions for the dilutions must be supplied with the samples,              •
        but the identity of the compounds in the ampoules must be supplied
        separately in sealed envelopes to the laboratory management.                   •
        Samples of this type are available from:                                       |

                        John A. Winter, Chief                                          •
                        Quality Assurance Branch                      .                 •
                        EMSL-Cincinnati                                                •
                        Environmental Protection Agency
                        Cincinnati, Ohio  45268                                        |

    2.   Obtain an environmental sample typical of the type normally analyzed
        in the laboratory.  Add the quality control samples to the                     •
        environmental samples according to the instructions provided, and              8
        proceed with the analyses using the appropriate method, e.g., as in
        Tests VII and VIII.                                                            -

    3.   Plot the total ion current profiles and identify all the compounds             ™
        using the mass spectra.  All compounds must be correctly identified
        except, as in the library search, isomers with nearly identical                8
       •70 ev electron ionization spectra should not be counted as incorrect.          •

X.  Solid Probe Inlet System Test (optional)                                           •

    The purpose of this test is to evaluate the critical thermal character-
istics of the solid probe inlet system, and to determine whether valid                _
spectra are produced with this system.  The test uses cholesterol which  is            I
sensitive to thermal effects.  Data acquisition is by continuous repetitive           *
measurement of spectra.

Procedure:             -,                                                               8

    1.  Prepare a standard solution of cholesterol  in acetone at a concen-            •
        tration of 250 micrograms per milliliter.  Evaporate one microliter           |
        of this solution in the solid probe sample holder.

    2.  Use the data acquisition parameters given in Test  I, and gradually            I
        heat the sample until the cholesterol pressure increases and  spectra          ™
        may be measured.

    3.  Terminate data acquisition and plot a background subtracted  spectrum          8
        of cholesterol as described in Test I.  Measure the  abundances  of
        the ions at masses 386 and 368, and compute the 386/368  abundance             •

                                      30
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ratio.  This should be 3.0 or greater for  an  acceptable solid probe
inlet system.  The ion abundance  at mass 369  should  be 26-34% of  the
abundance at mass 386.  Finally large ions above 30% relative
abundance should be at masses 41, 43, 55,  57,  67,  69, 71,  79, 81,
83, 91, 93, 95, 105,  107, 109, 119, 121, 133,  145, 147, 149, 159,
161, 213, 275, 301, and 386.
                             31

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                                  SECTION 4
                                                                                        I
                                                                                        I
                                                                                       I
                                  REFERENCES


1.  Eichelberger, J.W., L.E. Harris, and W.L. Budde, "Reference Compound to
    Calibrate Ion Abundance Measurements In Gas Chromatography - Mass
    Spectrometry Systems," Anal. Chera., 47_, 995 (1975).                                •

2.  Budde, W.L., and J.W. Eichelberger, "An EPA Manual for Organics Analysis
    Using Gas Chromatography - Mass Spectrometry," EPA Report No. EPA                . •
    600/8-79-006, March, 1979.                                                         |

3.  Budde, W.L., and J.W. Eichelberger, "Organics Analysis Using GC/MS," Ann           _
    Arbor Science Publishers, Ann Arbor, Michigan, July 1979.                          •

4.  "Guidelines Establishing Test Procedures for the Analysis of
    Pollutants," Federal Register                  .                              •     •

5.  "Handbook for Analytical Quality Control in Water and Wastewater
    Laboratories,*  EPA Report No. EPA-600/4-79-019, March, 1979, Chapter  6.           |




                                                                                      I


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                                      32

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                                  APPENDIX 17

                  LIFE CYCLE OF AN ON-SITE SYSTEM EVALUATION
  Approval  of
  Region  V's
  Managing
  Di rectors
            *r
N
/
Direction of
Re-Evaluation,
if Required
  Report  of Compliance
                              Agency Procedures
                              for Evaluations of
                              Monitoring Programs
Region V s QA Program
for Implementation of
Agency Procedures for
Evaluation of Monitoring
Programs	
                              Instructions
                              Evaluator
                                         for
Execution of On-Site
Evaluation
                              Results of On-Site
                              Evaluation
                                                Je
                              Report
                                      Evaluation
                             Meeting for Discussion
                             of Report and
                             Recommendations
                              Corretive Action
                              for Compliance
                                              >
                              Check of Results
                              after Compliance
                              Reports to
                              Management
                                      JL
                                         >
                              Monitoring Program
                              in Compliance with
                              Agency's Minimum
                              Quality Assurance
                              Requi rements
Di rections for
Special  On-Site
Evaluations
                               -£j Immedi.
                               HReport and Review
                                                             ->
                                 Task  Force
                                 for Compliance

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                                                                                I
                                 APPENDIX  18

         ELEMENTS FOR A SECTION  106,  208,  404(b)(l)  AND  GREAT  LAKES              _
           NATIONAL PROGRAM MONITORING  QUALITY  ASSURANCE PROGRAM                 •

1.  The laboratory shall  document and implement a  Quality Assurance  Policy
    to assure sufficient  quality control activities  are  maintained to  assure     •
    data credibility for each  monitoring project.  Management  or  supervisory     |
    quality control duties and responsibilities must be  defined for  its  own
    monitoring and for contract  projects.                                        «

2.  A Quality Assurance Coordinator shall  be  designated  by each laboratory
    to coordinate quality control activities  and to  assure that they are
    being performed.  If quality control is not practiced, then there  can       I
    be no quality assurance.                                                     I

3.  Documented, technique oriented collection procedures shall be implemented   •
    by each agency to assure valid and  representative samples  for surface       I
    waters, ground waters, point source discharges,  fish, sediment,  etc.
    Uniform record keeping will  be established  to  provide data credibility
    and sufficient "chain-of-custody".                                           I

4.  Field measurement methodologies shall  be  used  that are appropriate for
    each monitoring project.   Reference or approved  methods must  be  used        •
    for monitoring.  Calibration and preventive maintenance protocols  are       |
    to be established and used for all  field  instruments and methodologies.
    Records of the calibrations  and maintenance are  to be maintained.            —

5.  Sample preservation protocols shall be established by EPA  for consistency   •
    with the compositing time  period used  during monitoring, transport time
    between field and laboratory, and dictates  of  required laboratory            •
    methodologies, etc.                                                         |

6.  A uniform source of sample containers  shall be established.   Sufficient      _
    quality control will  be established to assure  the appropriateness  of        I
    containers used for each monitoring project.                                *

7.  Sufficient number of field and laboratory personnel  trained in quality      •
    control practices shall be available for  each  monitoring project.            |

8.  The laboratory will establish sufficient  record  keeping and sample          •
    handling practices for sample receipt  and analyses,  consistent with          I
    field record keeping practices, in  order  to maintain data  credibility
    and sufficient "chain-of-custody".

9.  Protocols will be established for and  records  will be kept of instrument     I
    calibration and maintenance  in an agency's  laboratory.  Appropriate
    protocols will be established and used to assure the acceptance  of          •
    designated laboratory prepared materials  (eg.  -  distilled  water) and        I
    purchased materials (eg.  -  microbiology media).
                                                                               I

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                           APPENDIX 18 (Continued)

10.   Each laboratory will  utilize and document methodologies,  appropriate  in
     precision, sensitivity and accuracy,  for each  monitoring  project.
     Reference or approved methods must be used for monitoring and are
     subject to review by  the QAO.

11.   Intra-laboratory audits of controls or "spiked" samples,  replicate
     analyses, and reagent blanks are to be utilized,  recorded,  and documented
     by each laboratory to assure the acceptance of data  for each  monitoring
     project.   Summaries or quality control charts  for these intra-laboratory
     audits can be utilized to document analytical  performance.  The ability
     of these intra-laboratory aidit data  to represent actual  data quality
     is dependent on the specific audits performed  and an understanding of
     their utility by a data user.

12.   Inter-laboratory audits of independently prepared reference smples or
     U.S. EPA quality control samples, when available, are to  be used at a
     minimum frequency of  quarterly and their results  documented as part of
     an agency's quality assurance program.  Inter-laboratory  audits or
     reference samples assure analytical accuracy and  maintenance  of
     calibration accuracy  of a laboratory's day-to-day intra-laboratory
     quality control program.

13.   Each laboratory is requested to participate in U.S.  EPA's performance
     sample program, usually scheduled once per year for  monitoring agencies.
     Results should be documented as part  of an agency's  quality assurance
     program and can replace one of the above inter-laboratory audits.

14.   A quality assurance program should assure that only  data  meeting
     acceptance criteria for the above elements are used  for each  monitoring
     project.   Data in computerized data management or storage systems  must
     be audited or verified as being the same as the actual  field  and
     laboratory results.

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                                 GLOSSARY


Analytical or reagent blank:  a blank used as a baseline for the analytical
     portion of a method.  For example, a blank consisting of a sample
     from a batch of absorbing solution used for normal  samples, but
     processed through the analytical system only, and used to adjust
     or correct routine analytical results.

Audit:   A systematic check to determine the quality of operation of some
     function or activity.  Audits may be of two basic types: (1) performance
     audits in which quantitative data are independently obtained for
     comparison with routinely obtained data, or (2) system audits of a
     qualitative nature that consist of an on-site review of a laboratory's
     quality assurance program and physical facilities for sampling,
     calibration and measurement.

Bioassay:  Using living organisms to measure the effect of a substance,
     factor, or condition.

Biomonitoring:  The use of living organisms to test water quality at a
     discharge site or downstream.

Blank or sample blank:  a sample of a carrying agent (gas, liquid, or solid)
     that is normally used to selectively capture a material of interest
     and that is subjected to the usual analytical or measurement process
     to establish a zero baseline or background value, which is used to
     adjust or correct routine analytical results.

Calculation:  The arithmetic conversion of raw analytical data to some
     standardized dimension form suitable for formating in a data report
     or for its final intended use.  For example, "x" ml/500 ml sample or
     reagent might be calculated to be 10 mg/liter of zinc chloride which
     exceeds the discharge limitations of a specific permit.

Calibration:  Establishment of a relationship between various calibration
     standards and the measurements of them by a measurement system (or
     portions thereof).  The levels of calibration standard should bracket
     the range of levels for which actual measurements are to be made.

Completeness:  The amount of valid data obtained from a measurement system
     compared to the amount that was expected to be obtained under correct
     normal operations.

Confidence interval:  A value interval that has a designated probability
     (the confidence coefficient) of including some defined parameter of
     the population.

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                                    2

Confidence limits:  The outer boundaries of a confidence interval.               I

Contract:  The legal instrument reflecting a relationship between  the            •
     Federal Government and a State or local government  or other recipient:      J
     (1) whenever the principal purpose of the instrument is  the acquisition,
     by purchase, lease, or barter, of property or services for the direct
     benefit or use of the Federal  Government; or (2)  whenever an  executive      I
     agency determines in a specific instance that the use of a type of          •
     procurement contract

Cooperative agreement:  The legal  instrument reflecting  the relationship        |
     between the Federal Government and a State or local  government or
     other recipient whenever: (1)  the principal  purpose of the relationship    _
     is the transfer of money, property, services, or  anything of  value          I
     to the State or local government or other recipient to accomplish          •
     a public purpose of support or stimulation authorized by Federal
     statute, rather than acquisition, by purchase, lease, or barter,  of        •
     property or services for the direct benefit or use  of the Federal          |
     Government; and (2) substantial involvement is anticipated between
     the executive agency acting for the Federal  Govenrment and the State       •
     or local government or other recipient during performance of  the            I
     contemplated activity.                                                     ™

Data validation:  A systematic effort to review data to  identify any            •
     outliers or errors and thereby cause deletion or  flagging of  suspect       •
     values to assure the validity of the data to the  user.  This
     "screening" process may be done by manual and/or  computer methods,          •
     and it may utilize any consistent technique such  as sample limits to       I
     screen out impossible values or complicated acceptable relationships
     of the data with other data.

In-house project:  A project carried out by EPA staff  in EPA  facilities.         I

Inter-laboratory:  Between two different laboratories.                           •

Intra-laboratory:  Within a given laboratory.

Measures of dispersion or variability:  Measures of the  differences,            •
     scatter, or variability of values of a set of numbers.  Measures  of        •
     the dispersion or variability are the range, the  standard deviation,
     the variance, and the coefficient of variation.                            •

Performance audit:  Planned independent (duplicate) sample checks  of
     actual output made on a random basis to arrive at a quantitative            _
                                                                                I

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     measure of the quality of the output.   These independent  checks  are
     made by an auditor subsequent to the routine checks by a  field
     technician or laboratory analyst.

Performance test sample:   A sample or sample concentrate (to be diluted
     to a specified volume before analysis)  of known (to the EPA only)
     true value which has been statistically established by inter!aboratory
     tests.  These samples are commonly provided to laboratories to  test
     analytical performance.  Analytical  results are reported  to the  EPA
     for evaluation.

Proficiency testing:  Special series of planned tests to determine the
     ability of field technicians or laboratory analysts who normally
     perform routine analyses.  The results  may be used for comparison
     against established criteria, or for relative comparisons among  the
     data from a group of technicians or analysts.

Program:  The technical office or staff that has responsibility for  a part
     of the Agency's operation.  For R&D grants, the "programs" are  the
     Office of Research and Development, the Office of Air Quality Planning
     and Standards, the Office of Solid Waste Management Programs, and
     the Office of Mobile Sources Air Pollution Control.

Project officer:  The EPA official designated in the grant or  contract
     agreement as the Agency's principal  contact with the grantee on  a
     particular grant.  This person is the individual responsible for
     project monitoring and for recommendations on or approval of proposed
     project changes.

Quality:  The totality of feature and characteristics of a product or
     service that bears on its ability to satisfy a given purpose.   For
     pollution measurement systems, the product is pollution measurement
     data, and the characteristics of major  importance are accuracy.
     precision, and completeness.  For monitoring systesm, "completeness",
     or the amount of valid measurements obtained relative to  the amount
     expected to have been obtained, is usually a very important measure
     of quality.  The relative importance of accuracy, precision, and
     completeness depends upon particular purpose of the user.

Quality Assurance:  (1) An organization's total  program for assuring  the
     reliability of the data it produces.

                    (2) A system for integrating the quality planning,
     quality assessment,  and quality improvement efforts of various  groups
     in an organization to enable operations to meet user requirements

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                                    ^

     at an economical  level.   In  pollution  measurement  systems,  quality          I
     assurance is concerned with  all of the activities  that have an
     important effect  on the  quality of the pollution measurements,  as well      •
     as the establishment of  methods and techniques  to  measure the quality       |
     of the pollution  measurements.  The more  authoritative usages
     differentiate between "quality  assurance"  and  "quality control",
     where quality control is "the system of activities to provide a            •
     quality product"  and quality assurance is  "the  system of activities         H
     to provide assurance that the quality  control  system is performing
     adequately".                                                               •

Quality assurance manual:  An orderly  assembly of management policies,
     objectives, principles,  and  general procedures  by  which an  agency           —
     or laboratory outlines how it intends  to  produce quality data.              •

Quality assurance plan:   An orderly  assembly of detailed and specific
     procedures by which an agency or  laboratory delineates how  is               •
     produces quality  data for a  specific project or measurement method.         I
     A given agency or laboratory would have only one quality assurance
     manual, but would have a quality  assurance plan for each of its            •
     projects or programs (group  of  projects using  the  same measurement          I
     methods; for example, a  laboratory service group might develop  a
     plan by analytical  instrument since the service is provided to  a
     number of projects).                                                       I

Quality control:  The  detailed and specific procedures  used to insure the
     quality of data produced by  a particular  measurement activity;  the          •
     system of activities designed and implemented  to provide a  quality          I
     product.

Quali ty control (internal):  The  routine activities  and checks,  such as          I
     periodic calibrations, duplicate  analyses, use  of  spiked sample, etc.,      •
     included in normal  internal  procedures to control  the accuracy  and
     precision of a measurement process.                                        •

Quality control (external):  The  activities which are performed  on an
     occasional basis, usually initiated and performed  by persons outside        _
     normal routine operations, such as on-site system  surveys,  independent      I
     performance audits, interlaboratory comparisons, etc., to assess            •
     the capability and performance  of a measurement process.

Range:  The difference between the maximum  and minimum  values of a set           |
     of values.  When  the number  of  values  is  small  (i.e., 12 or less), the
     range is a relatively sensitive (efficient) measure of variability.         _
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Reagent:  A chemical  material, usually a compound of high  purity,  which  is
     used as a reactant in the process of a chemical  analysis.

Recovery:  That percentage of a parameter in a sample which  is  detected
     or "recovered" from that sample during chemical  analysis.

Reliability:  A numerical statement of accuracy and precision.

Representativeness:  A numerical  statement of how well  a sample or group
     of samples or the data derived therefrom represents the actual
     parameter variations at the sampling point, plus how well  that
     sampling point represents the actual parameter variations  which
     are under study.

Sample:  A subset or group of objects or things selected from a larger
     set called the "lot" or "population".  The objects or things  may
     be physical, such as specimens for testing, or they may be data
     values representing physical samples.  Unless otherwise specified,
     all samples are assumed to be randomly selected.  Samples  can take
     numerous forms, such as:

     Representative sample:  A sample taken to represent a lot  or  population
     as accurately and precisely as possible.  A representative sample may
     be either a completely random sample or a stratified sample,  depending
     upon the objective of the sampling and the conceptual population for
     a given situation.

     Spiked sample:  A normal sample of material (gas,  solid, or liquid)
     to which is added a known amount of some substance of interest.   The
     extent of the spiking is unknown to those analyzing the sample.   Spiked
     samples are used to check on the performance of a  routine  analysis  or
     the recovery efficiency of a method.

Standard deviation:  The square root of the variance of a set of values:


                       n          9
                          (X1 - X)2

          s =          i = 1
                           n - 1
     if the values represent a sample from a larter population:

                       N
                           (Xi - u)2

                       i = 1

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     Calibration standard:   A standard  prepared  by  the  analyst  for  the
     purpose of calibrating an instrument.   Laboratory  control  standards
     are prepared independently from calibration standards  for  most methods.
     Detection limit:   That number obtained  by  adding two  standard deviations
     to the average value obtained for a  series  of  reagent  blanks that  are
     analysed over a long time period (several  weeks or months).
                                                                                I
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     where u is the true arithmetic  mean  of the  population.  The  property        |
     of the standard deviation that  makes it most  particularly meaningful
     is that it is in the same units as the values of the  set, and               •
     universal  statistical  tables  for the normal  (and other) distributions       I
     are expressed as a function of  the standard  deviation.  Mathematically,
     the tables could just  as  easily be expressed  as a  function of the
     variance.                                                                   I

Standard reference material  (SRM):   A material produced in quantity,  of
     which certain properties  have been certified  by the National Bureau         •
     of Standards (NBS) or other agencies to the  extent possible  to satisfy      J
     its intended use.  The material  should be in  a matrix similar to
     actual samples to be measured by a measurement system or be  used
     directly in preparing  such a  matrix.   Intended uses include:                I
     (1) standardization of solutions,  (2)  calibration  of  equipment,  and         ™
     (3) monitoring the accuracy and precision of  measurement systems.

Standard reference sample:   A  carefully prepared material  produced from or       |
     compared aganist an SRM (or other equally well characterized material)
     such that there is little loss  of accuracy.   The sample should have a       _
     matrix similar to actual  samples used  in the  measurement system.  These     I
     samples are intended for  use  primarily as reference standards to:           *
     (1) determine the precision and accuracy  of measurement  systems,
     (2) evaluate calibration standards,  and (3) evaluate  quality control       •
     reference samples.   They may be used "as  is"  or  as  a  component  of  a        |
     calibration or quality control  measurement  system.   Examples:  an
     NMS-certified sulfur dioxide permeation  device  is  an SRM.   When used       •
     in conjunction with an air dilution  device,  the resulting  gas  becomes      I
     an SRS.  An NBS-certified oxide gas  is an SRM.   When diluted with  air,
     the resulting gas is an SRS.

Standardization:  A physical  or mathematical  adjustment  or correction of a      I
     measurement system to make the  measurements  conform to predetermined
     values.  The adjustments or corrections  are  usually based  on a            •
     single-point calibration level.                                           I
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                                    7

     Duplication analyses:   The collection of two samples  from the  same
     field-site which are analyzed at  different times but  usually on  the
     same day.

     Laboratory control  standard:   A standard of known concentration
     prepared by the analyst.

     Reference standard:   A solution obtained from an outside source
     having a known value and  analyzed as a blind sample.

     Relative percent error for duplicate analyses:   The difference between
     the measured concentration for the duplicate pair times  100 and
     divided by the average of the concentration.

     Relative percent error for laboratory control standards:   The  difference
     between the measured value and the theoretically correct value times
     100 and divided by the correct value.

     Relative percent error of a reference sample analysis:   The difference
     between the correct  and measured  values times 100 and divided  by the
     correct concentration.

Standards based upon usuage:

     Calibration standard:   A  standard used to quantitate  the relationship
     between the output of a sensor and a property to be measured.
     Calibration standards should be traceable to standard reference
     materials or primary standard.

     Quality control reference sample  (or working standard):   A material
     used to assess the performance of a measurement or portions thereof.
     It is intended primarily  for routine intralaboratory  use in maintaining
     control of accuracy  and would be  prepared from or traceable to a
     calibration standard.

Standards depending upon  "purity"  or established physical  or  chemical  constants:

     Primary standard:  A material having a known property that is  stable,
     that can be accurately measured or derived from established physical
     or chemical constants, and that is readily reproducible.

     Secondary standard:   A material having a property that is calibrated
     against a primary  standard.

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Standards in naturally-occurring  matrix:   Standards  relating to  the  pollutant
     measurement portions of air  pollution measurement  systems may be            •
     categorized according to matrix,  purity,  or  use.   Standards in  a            |
     naturally-occurring matrix include  Standard  Reference  Materials and
     Standard Reference Samples.                                                 —

Statistical  control  chart (also Shewhart  control  chart):  A graphical  chart      •
     with statistical  control limits  and  plotted  values (usually in
     chronological  order) of some measured parameter for a  series of             •
     samples.  Use  of the charts  provides a visual display  of the pattern        |
     of the data, enabling the early  detection of time  trends and shifts
     in level.  For maximum usefulness in control, such charts should  be         m
     plotted in a timely manner,  i.e., as soon as the data  are available.        I

System audit:  A systematic on-site qualitative review  of facilities,
     equipment, training, procedures,  record-keeping, validation, and            •
     reporting aspects of total (quality  assurance)  system  to arrive at          I
     a measure of the capability  and  ability of the  system.  Even though
     each element of the system audit  is  qualitative in nature,  the              •
     evaluation of  each element and the total  may be quantified  and              I
     scored on some subjective basis.

Systematic error:  The condition  of a  consistent  deviation  of the results        I
     of a measurement process from the reference  or  known level.                 •

Test Variability:  Accuracy:  The degree  of agreement of a  measurement  (or       •
     an average of  measurements of the same thing),  X,  with an accepted          |
     reference or true value, T,  usually  expressed as the difference
     between the two values, X-T, or  the  difference  as  a percentage  of the       —
     reference or true value, 100(X-T)/T, and  sometimes expressed as a           I
     ratio,  X/T.                                                                •

     Bias:  A systematic (consistent)  error in test  results.  Bias can           •
     exist between  test results and the true value (absolute bias, or  lack       |
     of accuracy),  or between results  from different sources (relative
     bias).   For example, if different laboratories  analyze a homogeneous        •
     and stable blind sample, the relative biases among the laboratories         I
     would be measured by the differences existing among the results from        *
     the different  laboratories.   However, if  the true  value of  the  blind
     sample were known, the absolute  bias or lack of accuracy from the           I
     true value would be known for each  laboratory.                              I

     Precision:  A  measure of mutual  agreement among individual  measurements    •
     of the same property, usually under  prescribed  similar conditions.         I
     Precision is most desirably  expressed in  terms  of  the  standard
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     deviation but can be expressed  in  terms  of  the  variance,  range, or
     other statistics.  Various  measures  of  precision  exist depending upon
     the "prescribed similar conditions".

     Replicates:   Repeated but independent determinations of the same
     sample, by the same analyst,  at essentially the same time and same
     conditions.   Care should be exercised in considering replicates of a
     portion of an analysis and  replicates of a  complete analysis.  For
     example, duplicate titrations of the same digestion are not valid
     replicate analyses, although  they  may be valid  replicate  titrations.
     Replicates may be performed to  any degree,  e.g.,  duplicates, triplicates,
     etc.

     Rejproducibility:   The precision, usually expressed as a standard
     deviation, measuring the variability among  results of measurements
     of the same sample at different laboratories.

Validation:  A systematic effort to  review data  to identify outliers or
     errors and thereby cause deletion  or flagging of  suspect  values to
     assure the validity of the  user's  data.

Variance:  Mathematically, for a sample,  the  sum of  squares of the
     differences between the individual values of a  set and the arithmetic
     mean of the set,  divided by one less than the number of values.

Verification:  Follows validation  and permits the certification of the data
     for an intended legal use,  presuming that the chain-of-custody require-
     ments are found to be intact.   Again the terminology used in this
     document is intended to be  general and  should in  no way be construed
     to limit the use  of special  area terminologies  in the preparation
     of the required QA Plan.

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                                    TECHNICAL REPORT DATA
                            (Please read Instructions on the reverse ve/ore completing)
1. REPORT NO.

  EPA-905/4-80-001
                                                             3. RECIPIENT'S ACCESSION-NO.
4. TITLE AND SUBTITLE
  Quality Assurance Program, Guidelines and
  Specifications, Criteria and Procedures,
  Region V
                  5. REPORT DATE
                     January 15, 1980
                  6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)

  James H.  Adams, Jr.
                                                             8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
  Quality Assurance Office
  Surveillance and Analysis  Division
  U.S.  Environmental  Protection Agency
  Chicago, Illinois 60605
                                                             10. PROGRAM ELEMENT NO.
Region V
                  11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
  Quality Assurance  Office
  Surveillance and Analysis Division
  U.S. Environmental  Protection Agency
  Chicago,  Illinois  60605
                  13. TYPE OF REPORT AND PERIOD COVERED
                     Manual
 Region V
                  14. SPONSORING AGENCY CODE
15.SUPPLEMENTALY^NOTES  Manuai  wi 11 be reproduced  in the current format  (plastic Dinding)
  maintained up-to-date by the QAO, Region  V.   Distribution will be to  Agency personnel
  and its contractors,  State and local agency laboratory Directors and  QC offices in
                                                              	Rag-i-nit V	
                                                                               i\cy i VJM r;
16. ABSTRACT

  This manual documents  the Quality Assurance  Program for Region V,  U.S.  EPA, that will
  produce a numerical  estimate'of the reliability of all data values reported or used
  by the Region.   Revisions will be made per the requirements of the finalized Quality
  Assurance Plan  of  the--Agency.   The elements  of a quality assurance program are
  discussed,  including Region V's QA Policy Statement, Objectives and Milestones,
  Quality Assurance-Management,  Personnel, .Facilities, Equipment and Services, Review
  of Program  Plans,  Project Plans'or Study Plans, Data Collection, Data Processing,
  Corrective  Actions,  Data Quality Assessment, Data Quality Reports, Chain of Custody
  and Specific  Guidance.
                                KEY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
    b.IDENTIFIERS/OPEN ENDED TERMS
c.  COSATI Field/Group
  Quality Assurance
  Quality Control
     Intralaboratory QC
     Inter!aboratory QC
     Performance and 'System
       Audits
     Quality Control Program
     Accuracy  Assessment
     Precision Assessment
   13B
   14B
18. DISTRIBUTION STATEMENT

   Release Unlimited
     19. SECURITY CLASS (This Report)
     Unclassified
21. NO. OF PAGES
    237
                                               20. SECURITY CLASS (Thispage)

                                                Unclassified
                                22. PRICE
    EPA Form 2220-1 (3.73)

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                                                          INSTRUCTIONS

      1.   REPORT NUMBER
          Insert the EPA report number as it appears on the cover of the publication.

      2.   LEAVE BLANK

      3.   RECIPIENTS ACCESSION NUMBER
          Reserved for use by each report recipient.

      4.   TITLE AND SUBTITLE
          Title should indicate clearly and briefly the subject coverage of the report, and be displayed prominently. Set subtitle, if used, in smaller
          type or otherwise subordinate it to mam title. When a report is prepared in more than one volume, repeat the primary title, add volume
          number and include subtitle for the specific title.                                                          ,

      5.   REPORT DATE
          Each report shall carry a date indicating at least month and year. Indicate the basis on which it was selected (e.g., date of issue, date of
          approval, date of preparation, etc.),

      6.   PERFORMING ORGANIZATION CODE
          Leave blank.

      7.   AUTHOR(S)
          Give name(s) in conventional order (John R. Doe, J. Robert Doe, etc.).  List author's affiliation if it differs from the performing organi-
          zation.

      8.   PERFORMING ORGANIZATION REPORT  NUMBER
          Insert if performing organization wishes to assign this number.

      9.   PERFORMING ORGANIZATION NAME AND ADDRESS
          Give name, street, city, state, and ZIP code. List no more than two levels of an organizational hiiearchy

      10.  PROGRAM ELEMENT NUMBER
          Use the program element number under which the report was prepared. Subordinate numbers may be included in parentheses.

      11.  CONTRACT/GRANT NUMBER
          Insert contract or grant number under which report was prepared.

      12,  SPONSORING AGENCY NAME AND ADDRESS
          Include ZIP code.

      13.  TYPE OF REPORT AND PERIOD COVERED
          Indicate interim final, etc., and if applicable, dates covered.                          -     *

      14.  SPONSORING AGENCY CODE
          Leave blank.

      •15.  SUPPLEMENTARY NOTES                  " "               .       -   -    -     -   '
          Enter information not included elsewhere but useful, such as:  Prepared in cooperation with. Translation of. Presented at conference of,
          To be published in, Supersedes. Supplements, etc.

      16.  ABSTRACT
          Include a brief (200 words or less) factual summary of the most significant information contained in the report. If the report contains a
          significant bibliography or literature survey, mention it here.

      17.  KEY WORDS AND DOCUMENT ANALYSIS
          (a) DESCRIPTORS - Select from the Thesaurus of Engineering and Scientific  Terms the proper authorized terms that identify the major
          concept of the research and are sulficiently specific and precise to be used as index entries for cataloging.
          the primary posting(s).
      18. DISTRIBUTION STATEMENT
          Denote releasability to the public or limitation for reasons other than security for example "Release Unlimited." Cite any availability to
          the public, with address and price. ,

      19. & 20. SECURITY CLASSIFICATION
          DO NOT submit classified reports to the National Technical Information service.

      2t. NUMBER OF PAGES
          Insert the total number of pages, including this one and unnumbered pages, but exclude distribution list, if any;    ....

      22. PRICE
          Insert the price set by the National Technical Information Service or the Government Printing Office, if known.
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          (b) IDENTIFIERS AND OPEN-ENDED TERMS - Use identifiers for project names, code names, equipment destenators, etc. Use open-     I
          ended terms written in descriptor form for those subjects for which no descriptor exists.                                              •

          (c) COSATI FIELD GROUP - Field and group assignments are to be taken from the 1965 COSATI Subject Category List.  Since the ma-
          jority of documents are muitidisciclinary in nature, the Primary Field/Group assignment!*) will be specific discipline, irea  of human         a
          endeavor, or type of physical object.  The appucation(s) will be cross-referenced with secondary Field, Group assignments that will follow    •
I

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S                                       U.S.  Environmental  Protection
                                        Great Lakes  Kntloral  Program Offtee
              •••----          •  •             GLNTO  Library                           '                              •
  EPA Form 2220-1 (9-73) (Reverse)                                                                                                  |

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